What will the term “remuneration” mean under the pay transparency regulations?
The directive adopts a very broad understanding of “remuneration”, far beyond “basic salary”.
Under the pay transparency regulations, a broad definition of “remuneration” will apply. It will be similar to the one currently provided for in Article 18(3c) § 2 of the Labor Code. This concept will therefore include all components of remuneration, regardless of their name and nature, as well as other work-related benefits granted to employees in monetary or non-monetary form.
This means that in practice, when performing duties related to pay transparency (e.g. calculating the pay gap or informing employees about average pay levels in their category), it will be necessary to take into account not only the “basic salary”, but also any other supplementary or variable components: bonuses, awards, travel discounts, housing and food allowances, compensation for participation in training or benefits in kind (e.g. a company car or company apartment).