For many reward and HR leaders, pay transparency in the UK starts with a real worry. If you publish a range or explain a pay decision, will it hold up when candidates and colleagues ask questions? The answer rests on what sits beneath the range: consistent job levels and internal equity checks.
This piece draws on Inside a Pay Transparency Journey, a CTF session from October 2025 with Rob Johnston, Director of Reward, Data and Facilities, Danone UK and Ireland. The discussion covered the groundwork that makes pay easier to explain, from job levels to manager conversations.
Why UK pay transparency starts with job levels
A published range is only one part of transparency. People also need to understand how the business compares roles and makes decisions. If two roles share a title but not the same duties, no range will make sense to the people in them.
Job evaluation compares what roles demand. The method you choose matters less than applying it consistently, so that each role has a sound level before you look at pay. Clear, gender-neutral role descriptions help too, because old titles and local habits can skew the picture.
Ownership matters as much as method. Decide who maintains the structure, who reviews exceptions and who approves changes. Then test your own grades and role families. Do they give you a sound basis for pay decisions? If not, fix the unclear comparisons before you publish more.
Know what your pay gap figure is telling you
It is easy to confuse an overall gender pay gap with a pay equity analysis, but they do not answer the same question. The overall gap compares average pay across groups, so the mix of roles and levels can drive the result. It does not, by itself, compare like with like.
A pay equity analysis asks a narrower question: are people doing comparable work paid fairly, once you allow for legitimate reasons for a difference? The answer depends heavily on how the analysis was built. So before you act on any result, check who was included, which parts of pay were counted and what the analysis allowed for.
Data is often the sticking point. Pay information rarely sits in one place, and each system can have its own owner. So bring the relevant data together first, and agree your definitions before you analyse anything. Then write down your method so you can repeat it after each pay cycle. For the UK reporting rules themselves, GOV.UK publishes gender pay gap reporting guidance for employers.
Test every decision for internal equity
A published range is visible to your current colleagues as well as to candidates. So before you publish one, check it against what people doing comparable work already earn, and decide how you would explain any difference.
The same check applies to every new hire, promotion and lateral move. Record the reason for any difference, and note if a wider pay change needs review. Then revisit the position after each pay cycle, because later decisions can undo good analysis. Our article on new starter onboarding looks at the same tension, including who should own advertised ranges.
Progression raises the same question from the other side. Can a manager explain why someone sits where they do in a range, and what would justify a move? If the answer depends on who you ask, write down the criteria you use. Then check that every manager applies them in the same way.
Get managers ready for the questions
More visible pay brings more questions. Managers need practical guidance. They also need a clear route to HR or reward support when they cannot answer one. Start with the pay conversations they already face. Help them explain the grade for a role and where an offer sits in the range. They should not promise progression that nobody has agreed.
Agree in advance how you will handle concerns, exceptions and missing data. If a manager cannot explain a decision with confidence, they should pass it on rather than improvise an answer.
Questions to take to your team:
- Which pay decision would our managers find hardest to explain?
- Do our grades give us a sound basis for comparing roles?
- Where does each pay element sit, and who owns that data?
- When did we last compare an advertised range with what similar colleagues earn?
The full session
Members can watch the recording of this session, download the slides and read the member ebook. The ebook includes two practical worksheets: one to map your pay data and one to review a pay decision. You will find it all in the CTF Session Library. If you lead People work in a consumer business, apply to join or see what membership includes.
