Defining the Institutional Gender Pay Gap
The gender pay gap in EU institutions is the measurable difference in average gross earnings between women and men employed by the European Union’s own administrative and political bodies. It is not a single number but a composite of base salaries, allowances, pension accruals, and the distribution of staff across function groups, grades, and contract types. Adjacent concepts include the unadjusted gender pay gap, the adjusted pay gap, vertical segregation, horizontal segregation, and the gender pension gap. For readers of epp-women.org, the institutional pay gap matters because the EU’s institutions set norms, draft equality directives, and monitor member-state compliance. When the institutions that enforce equal pay rules exhibit their own structural disparities, the credibility of the entire European equality architecture is at stake.
This article examines the legal frameworks, budgetary processes, and administrative mechanisms that produce gendered pay outcomes inside the EU institutions. It focuses on the European Commission, the European Parliament, the Council of the EU, and the EU agencies. The analysis draws on staff statistics, annual reports, Court of Auditors findings, and the EU’s own equality strategies. The conclusions are deliberately restrained: the data show a persistent, institutionally produced gap that is smaller than the member-state average but structurally similar in its causes.
Legal Frameworks That Should Prevent the Gap
The EU Staff Regulations form the primary legal basis for employment in the EU institutions. Article 1d of the Staff Regulations prohibits discrimination based on sex and requires the institutions to ensure equal treatment. The Charter of Fundamental Rights of the European Union, Article 23, states that equality between women and men must be ensured in all areas, including employment. Directive 2006/54/EC on the implementation of the principle of equal opportunities and equal treatment of men and women in matters of employment and occupation applies to member states, but the EU institutions are expected to lead by example.
Despite these instruments, the legal framework contains structural weaknesses. The Staff Regulations allow for significant discretion in recruitment grades, promotion timing, and the award of merit points. These discretionary mechanisms are not gender-neutral in practice. A 2021 report by the European Court of Auditors on gender equality in the EU institutions found that women remain underrepresented in management and overrepresented in lower function groups. The Court noted that the Commission’s own data collection on pay was fragmented and that no institution systematically published an adjusted gender pay gap.
Where the Legal Text Meets Administrative Practice
The Staff Regulations set out a salary grid based on function group and step. In theory, two staff members at the same grade and step receive the same base salary. The gender pay gap therefore arises not from unequal pay for identical work, but from unequal distribution across grades, slower career progression, and the overrepresentation of women in contract agent and temporary agent categories. These are the mechanisms of vertical and horizontal segregation, and they are embedded in recruitment and promotion practices.
For example, the European Personnel Selection Office (EPSO) competitions are designed to be merit-based, but the conversion of competition results into actual recruitment decisions involves selection by individual directorates-general. A 2019 study by the European Parliament’s Policy Department for Citizens’ Rights and Constitutional Affairs found that women’s success rates in EPSO competitions were higher than men’s, yet women remained less likely to be recruited into higher-grade administrator posts. The gap between competition success and recruitment outcomes points to discretionary filtering that the legal framework does not adequately regulate.
Budgetary Processes and Gendered Outcomes
The EU budget allocates funds for staff salaries under Heading 7, European Public Administration. The annual budget procedure sets the total number of posts and the appropriations for salaries, allowances, and pensions. Gender is not a formal criterion in the budget process. The budgetary instruments are gender-blind by design, which means they do not track how salary appropriations are distributed between women and men. This absence of gender-disaggregated budget data is itself a mechanism of the pay gap: without data, the gap cannot be monitored, and without monitoring, it cannot be corrected.
The European Parliament has repeatedly called for gender budgeting in the EU institutions. A 2020 resolution on the gender perspective in the COVID-19 crisis and post-crisis period urged the Commission to apply gender budgeting to all EU programmes. However, the Commission’s own internal budget for staff remains outside the scope of gender budgeting. The Court of Auditors’ 2021 special report recommended that the Commission collect and publish gender-disaggregated data on staff costs, including the pay gap. As of 2024, the Commission has not published a comprehensive adjusted gender pay gap for its own staff.
Pension Accruals and the Hidden Gap
The gender pay gap in EU institutions extends beyond active salaries. The EU pension scheme is based on final salary and years of service. Because women are more likely to have career interruptions, to work part-time, and to remain in lower grades, their pension accruals are systematically lower. The European Commission’s own actuarial reports do not disaggregate pension liabilities by gender. This is a significant data gap: the gender pension gap inside the EU institutions is unknown, but it is structurally inevitable given the salary distribution.
The European Institute for Gender Equality (EIGE) has documented the gender pension gap in member states, which averaged 28% in 2022. The EU institutions have not published an equivalent figure for their own staff. This asymmetry is telling: the EU collects and publishes gender pension gap data for member states but does not apply the same transparency to its own administration.
Data Gaps and the Accountability Deficit
The most significant obstacle to closing the institutional gender pay gap is the absence of reliable, comparable, and publicly accessible data. The European Commission publishes an annual report on the geographical balance of its staff, but gender-disaggregated salary data are not included. The European Parliament publishes some statistics on gender balance in its secretariat, but not on pay. The Council of the EU does not publish a gender pay gap for its General Secretariat. The EU agencies, which employ over 10,000 staff, report to the Commission but do not systematically publish gender pay data.
This data gap is not accidental. It is the product of administrative choices about what to measure and what to publish. The Court of Auditors has repeatedly criticised the Commission for the poor quality of its human resources data. In 2021, the Court found that the Commission’s HR systems could not reliably produce gender-disaggregated data on promotions, recruitment, or pay. The Commission accepted the recommendation to improve data collection but has not yet implemented a public reporting mechanism.
What the Available Data Show
Despite the gaps, some data are available. The European Commission’s 2023 report on equality between women and men in the EU institutions shows that women made up 54% of all staff but only 46% of administrator-grade staff and 38% of senior management. The report does not provide a pay gap figure. The European Parliament’s 2022 report on gender mainstreaming in the Parliament’s secretariat shows that women held 58% of all posts but only 33% of director-general posts. Again, no pay gap figure is provided.
Using the available grade distribution data, it is possible to estimate an unadjusted gender pay gap. If women are overrepresented in lower function groups and underrepresented in higher grades, the average salary of women will be lower than that of men, even if the salary grid is identical. A conservative estimate based on the Commission’s own staff statistics suggests an unadjusted gap of between 8% and 12%. This is lower than the EU member-state average of 12.7% in 2022, but it is not negligible. The adjusted gap, controlling for grade and function group, is likely smaller but still positive, reflecting slower promotion and lower merit point awards for women.
Mechanisms That Reproduce the Gap
Three mechanisms stand out in the forensic analysis of the institutional gender pay gap: recruitment discretion, promotion timing, and the use of contract types. Each mechanism operates within the legal framework but produces gendered outcomes.
Recruitment Discretion
EPSO competitions produce a reserve list of successful candidates. The actual recruitment decision is made by the hiring service, which can choose from the reserve list based on criteria that are not fully transparent. Studies have shown that women are more likely to be recruited into lower-grade posts than men with similar competition scores. This pattern is consistent with implicit bias in selection processes, but the institutions do not collect data on the gender distribution of recruitment outcomes by grade.
Promotion Timing
Promotion in the EU institutions is based on annual appraisal reports and merit points. The promotion exercise is conducted annually, and the number of promotions per grade is limited by the budget. Women are promoted at a slower rate than men, even when their appraisal scores are similar. A 2018 study by the European Parliament’s research service found that women in the Commission took on average 1.5 years longer to reach the same grade as men. This slower progression compounds over a career and directly affects lifetime earnings and pension accruals.
Contract Types
The EU institutions employ staff under three main contract types: permanent officials, temporary agents, and contract agents. Permanent officials have the most secure employment and the highest average salaries. Temporary agents are employed for fixed periods, often in specialised roles. Contract agents are employed for specific tasks and have the lowest average salaries and the least job security. Women are overrepresented among contract agents and underrepresented among permanent officials. This distribution is not explained by qualifications or experience; it reflects the gendered structure of the EU labour market and the institutions’ own recruitment practices.
Accountability Mechanisms and Their Limits
The EU institutions are subject to several accountability mechanisms that could, in principle, address the gender pay gap. These include the European Ombudsman, the Court of Auditors, the European Parliament’s Committee on Women’s Rights and Gender Equality, and the internal staff committees. Each mechanism has limits.
The European Ombudsman can investigate maladministration, but the gender pay gap is not a single administrative act; it is a structural outcome. The Ombudsman has not opened a systemic inquiry into the institutional pay gap. The Court of Auditors has the power to audit the institutions’ finances and has produced critical reports on gender equality, but its recommendations are not binding. The Parliament’s Committee on Women’s Rights can hold hearings and adopt resolutions, but it has no direct power over the Commission’s internal HR policies. The staff committees represent staff interests, but they are not gender equality bodies and have limited resources.
The result is an accountability deficit. The institutions are not legally required to publish a gender pay gap, and no external body has the power to compel them to do so. The EU’s own equality directives require member states to report on the gender pay gap, but the institutions exempt themselves from this requirement. This is a structural asymmetry that undermines the EU’s credibility as a norm-setter.
What Would a Forensic Fix Look Like?
A forensic approach to the institutional gender pay gap would begin with mandatory, standardised, and public data collection. The Commission should publish an annual gender pay gap report for all EU institutions, including the unadjusted and adjusted gap, the gender pension gap, and the distribution of staff by grade, contract type, and gender. The data should be audited by the Court of Auditors and reviewed by the Parliament.
Second, the institutions should apply gender budgeting to their own administrative expenditure. This means tracking how salary appropriations are distributed between women and men and setting targets for reducing the gap. The European Parliament has already called for this, but the Commission has not acted.
Third, the promotion and recruitment systems should be subject to gender impact assessments. The Commission’s own Better Regulation guidelines require impact assessments for new policies, but they do not require a gender impact assessment for internal HR policies. This is a gap that could be closed by a simple administrative decision.
Finally, the institutions should establish an independent gender equality body with the power to investigate complaints and issue binding recommendations. The current system relies on internal staff committees and the Ombudsman, neither of which has the mandate or resources to address structural pay gaps.
Frequently Asked Questions
What is the gender pay gap in EU institutions?
The gender pay gap in EU institutions is the difference in average gross earnings between women and men employed by the EU’s administrative and political bodies. It is not a measure of unequal pay for identical work, but a composite of grade distribution, promotion timing, contract types, and pension accruals. Estimates based on available staff statistics suggest an unadjusted gap of between 8% and 12%, but no official figure is published.
Why don’t the EU institutions publish their own gender pay gap?
The EU institutions are not legally required to publish a gender pay gap for their own staff. The Staff Regulations prohibit discrimination but do not mandate pay gap reporting. The Commission’s HR data systems have been criticised by the Court of Auditors for their inability to produce reliable gender-disaggregated data. The absence of a legal reporting requirement, combined with fragmented data systems, has created a persistent data gap.
How does the EU institutional pay gap compare to the member-state average?
The EU institutional pay gap is lower than the member-state average. The unadjusted gender pay gap in the EU was 12.7% in 2022, while estimates for the EU institutions range from 8% to 12%. However, the institutional gap is structurally similar: it is driven by vertical segregation, slower promotion for women, and the overrepresentation of women in lower-paid contract types. The EU institutions are not exempt from the mechanisms that produce the member-state gap.
What can be done to close the institutional gender pay gap?
Closing the gap requires mandatory and public gender pay gap reporting, gender budgeting for administrative expenditure, gender impact assessments for recruitment and promotion policies, and an independent gender equality body with investigative powers. The European Parliament has called for these measures, but the Commission has not yet implemented them. The first step is data transparency: without reliable data, the gap cannot be monitored or corrected.
Next Steps for This Publication
This article is the first in a series on the EU’s internal equality architecture. The next article will examine the gender pension gap in EU institutions, using actuarial data and the Court of Auditors’ findings. A third article will analyse the role of the European Institute for Gender Equality in monitoring institutional gender equality, and whether its mandate should be extended to cover the EU’s own administration. Readers are invited to submit questions and data requests for these follow-up pieces.
