Promotion to Senior. New title, new business card, new stakeholder visibility. The pay number is decided two weeks later in a conversation between HR and the line manager — by reference to budget, rarely to the role architecture.

That two-week gap is where most of the directive's open questions on career progression live. Most companies couple promotion and pay by convention rather than by documented rule: a promotion typically comes with a raise; the size is set ad hoc; the new band position is rarely a deliberate choice. The convention works until the convention is examined.

Article 4 of Directive 2023/970 examines categories of equal work or work of equal value. A promotion-induced level change reshapes which category the employee belongs to. The pay position within the new category is what the directive's per-category metrics will measure.

Four common promotion-pay disconnects

01Promotion without pay change
The employee is promoted to Senior; their pay stays at their previous Mid position. The new role band has a higher floor than their current pay. They are now below the band floor for their new level — observable in the Article 9 per-category metrics as a low-position outlier.
02Pay change without promotion
The employee receives a substantial raise that pushes them above their current band's ceiling. The role hasn't changed; the title hasn't changed; but the compensation now sits in the next band up. The misalignment surfaces in the band integrity check and the Article 7 comparator analysis.
03Internal promotion at external rates
The employee is promoted internally; the pay adjustment is set at the level the company would pay an external hire for that role. The new position sits well above existing same-level employees who weren't promoted recently. Compression case built into the promotion itself.
04Promotion-by-title
The promotion is to a higher-status title without corresponding scope change. The pay adjustment may be modest because the work hasn't materially changed. Defensible if documented — but the title change can produce expectation gaps with the same-titled cohort elsewhere in the company.

What a defensible promotion-pay relationship looks like

The directive does not prescribe how promotion and pay should be linked. It requires that whatever link exists be documented and applied consistently. Three practical patterns:

Documented promotion-band relationship. The promotion moves the employee into the new band's floor (or some defined position above it — e.g., 5% above floor). The relationship is the same across all promotions and all employees. The promotion-pay outcome is predictable from the role architecture.

Documented promotion-percentage. The promotion increases pay by a defined percentage (typically 8-15%, depending on the level gap). Same percentage regardless of who is promoted. Bypasses the band-positioning question but introduces band-misalignment risk if the previous position was anomalous.

Documented promotion-target. The promotion targets a specific position within the new band (e.g., new band P25 for first-promotion-into-level, new band P50 for repeat-promotions). The target is the same across employees; the percentage required to hit it varies.

All three are defensible. What is not defensible is "the manager decides" without a documented framework — the lack of structure is what an Article 10 assessment examines.

The gender-asymmetry pattern in promotions

Promotion rates vary by gender in many companies. The most common pattern in European SMEs: men are over-represented in promotions at certain career-stage transitions (junior-to-mid, manager-to-director). The cumulative effect over years produces level-distribution asymmetry — the source of much of the headline gender pay gap in many companies.

The promotion-pay relationship interacts with this in two ways:

Either way, the underlying promotion-rate asymmetry surfaces in the report. The promotion-pay design determines which form it takes.

Worth noting

The directive does not ask whether promotion rates are gender-balanced — that is a different question handled under Article 6 (transparency of career progression policy) and separate gender-equality frameworks. Article 9's metrics measure the resulting pay distribution. Promotion-pay design is the mechanism that translates promotion patterns into pay patterns. Both are observable; both are documentable; both are examinable.

What needs to be in the record

For each promotion, three items should exist in the documentation:

  1. The promotion criteria. Why this employee was promoted at this time. The criteria themselves must be gender-neutral by design and applied consistently.
  2. The pay adjustment rationale. Why the new pay position is what it is. References the documented promotion-band relationship (or equivalent) and any specific factors (geography, performance signal, scarcity).
  3. The cohort positioning. Where the new pay sits relative to existing same-level employees. Above P75 of the cohort flags compression; below P25 flags band-floor anomaly.

These three items make the promotion auditable. They produce the record an Article 10 assessment would examine. They are the same three items the Article 7 right-to-information requester will indirectly probe when they ask for comparator pay information.

The promotion happens once. The compensation record it produces is read every year for as long as the employee is in the new category.
Enterprise compensation platforms track the promotion event. The pay decision it spawned, two weeks later, sits in a different system and is rarely cross-referenced. The disconnect is the platform; the disconnect is what the directive examines.

Where the diagnostic starts

Reviewing the promotion-pay relationship requires the role architecture to be documented and the historical promotion record to be reconstructable. PayGapCheck™ produces the analytical report on the current salary file — including the band-position distribution by level, which surfaces promotion-induced anomalies (low-position outliers, above-ceiling positions, cohort compression) in the current state.

The record speaks

What the promotion actually did to the pay distribution.

PayGapCheck™ takes the salary file and surfaces band-position distribution by level. Promotion-induced anomalies show up where they live: the band positions themselves.

Start the analysis →