Fair Pay Certificate

The Universal Fair Pay Check® Certification System

The central public reference for the Universal Fair Pay Check® certification system, its requirements, governance, audit framework, and public transparency mechanisms.

Table Of Contents

The Universal Fair Pay Check® Certification System

The EU certification mark for fair pay

The UNIVERSAL FAIR PAY CHECK® is an EU certification mark for fair pay, registered by the European Union Intellectual Property Office under No. 018618157.

The certification mark confirms that an organization has submitted its compensation system to regular analysis and review in accordance with the published Regulations of Use. Certification is based on documented evidence and current pay data.

Certification is valid for one year. Continued certification requires a new analysis, current evidence, and a new review. The certification level is determined from the evidence submitted for each certification period.

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What is assessed?

The UNIVERSAL FAIR PAY CHECK® assesses measurable fair pay outcomes through the analysis of compensation structures and pay gaps.

The analysis includes, at minimum:

the unadjusted gender pay gap;
the adjusted gender pay gap, taking account of function, level, and requirements;
statistical anomalies within compensation structures;
base pay;
bonuses and special payments;
total compensation.

The analysis covers all employees. Where the full employee population cannot be included, the organization documents the scope and explains the limitation.

Organizations may also analyze further pay gaps where the data and applicable legal framework permit this.

The certification level is determined from the submitted analysis results and the requirements defined in the Regulations of Use. Fair pay is not inferred from policies, intentions, or narrative commitments.

For adjusted analyses, organizations document the variables used to explain pay differences and provide a rationale for their inclusion. A statistical explanation does not in itself establish that a pay difference is fair. The relevance and appropriateness of the variables and the consistency of the supporting rationale form part of the certification review.

Why an EU certification mark?

An EU certification mark distinguishes goods or services that meet defined characteristics from those that have not been certified against those characteristics.

For the UNIVERSAL FAIR PAY CHECK®, the certified characteristics, conditions of use, authorized users, assessment process, monitoring, and sanctions are set out in publicly available Regulations of Use. This enables organizations and stakeholders to understand what has been assessed, which requirements apply, and for which period the certification mark may be used.

Certification levels

The UNIVERSAL FAIR PAY CHECK® has three certification levels. The levels build upon each other. Each successive level includes the requirements of the preceding certification level and adds further requirements based on current evidence.

Fair Pay Analyst

Fair Pay Analyst confirms that the organization has established the analytical basis required by the certification system.

The organization has:

analyzed its compensation structures;
included all employees or documented and explained a limitation of scope;
calculated the unadjusted and adjusted gender pay gaps;
analyzed base pay, bonuses, special payments, and total compensation;
identified statistical anomalies;
identified appropriate measures based on the analysis results.

Fair Pay Developer

Fair Pay Developer includes all requirements of Fair Pay Analyst and confirms compliance with the additional requirements applicable to Fair Pay Developer.

The organization has:

developed measures based on the analysis results;
documented implementation and reported on effectiveness;
reviewed the measures and adjusted them where required;
conducted a current pay analysis;
demonstrated an adjusted gender pay gap within the range of −1.00 to +1.00 percent.

Fair Pay Leader

Fair Pay Leader includes all requirements of Fair Pay Analyst and Fair Pay Developer and confirms compliance with the additional requirements applicable to Fair Pay Leader.

The organization has:

met the requirements of Fair Pay Analyst and Fair Pay Developer, including the adjusted gender pay gap range of −1.00 to +1.00 percent;
demonstrated an unadjusted gender pay gap within the range of −10.00 to +10.00 percent;
continued measures aimed at bringing the unadjusted gender pay gap toward zero;
reviewed the effectiveness of its measures and adjusted them where required;
conducted a current pay analysis;
communicated its fair pay work externally;
participated in best practice exchange.

All certification levels are reassessed during annual recertification. A previously awarded level is not carried forward automatically.

How certification works

Organizations conduct a compensation analysis and submit the required results and documentation to the FPI Fair Pay Innovation Lab.

Organizations may use a tool listed in the FPI Tool Compass, work with an FPI analysis partner or another consultancy, or use an internal tool or methodology.

A tool or methodology that has not yet been audited within the FPI framework requires an independent audit before its analysis results can be accepted for certification. External auditors review the methodology and data requirements against the requirements of the certification system and provide a final audit report to the FPI. A third-party tool already listed in the FPI Tool Compass does not require a new audit for each organization using it.

The FPI administers the certification process, checks whether the submitted documentation is complete, and may request clarification or additional information where required.

The FPI Screening Board reviews the submitted application and evidence and determines the certification level achieved.

Successful organizations receive a certificate and the corresponding certification mark. The certificate identifies the certified organization or organizational entity, the certification level, and the applicable certification period. The certification mark identifies the certification level and the applicable certification period.

Certification integrity

The integrity of the certification system is supported by a combination of:

publicly available Regulations of Use;
defined requirements for each certification level;
independent audits of tools and methodologies where required;
review by the FPI Screening Board;
annual recertification based on current evidence;
monitoring and defined sanctions;
public disclosure of certified organizations and their current certification status.

These elements establish a documented framework for the assessment, award, monitoring, and authorized use of the certification mark.

Certification governance

The FPI Fair Pay Innovation Lab gGmbH is the proprietor of EU certification mark No. 018618157 and administers the certification system. The FPI does not certify itself under the UNIVERSAL FAIR PAY CHECK®.

The FPI Screening Board safeguards the integrity, consistency, and credibility of certification decisions. It reviews applications and supporting evidence, determines certification levels, and supports the consistent application of the certification requirements.

In reviewing adjusted analysis results, the FPI Screening Board considers not only whether pay differences can be statistically explained, but also whether the variables used and the organization’s rationale for their use are appropriate within the certification framework. The Board may question variables, request further explanation or evidence, and require clarification before determining the certification level.

Fair pay does not require the absence of all differences. It requires differences to be transparent, evidence-based, consistently assessed, and subject to independent review.

The Regulations provide for an FPI Screening Board of three to seven members appointed for a term of 24 months. The current FPI Screening Board operates with seven members: six external experts and one representative of the FPI. The current members of the FPI Screening Board, their professional backgrounds, and fields of expertise are published on the FPI website.

The FPI Screening Board may:

review applications and submitted evidence;
request additional information;
examine extracts from analysis results and information about the method or tool used;
conduct sample-based checks;
determine the certification level;
review current evidence during recertification;
apply the measures defined in the Regulations where requirements are no longer met or the certification mark is misused.

Annual certification and recertification

Certification is valid for one year.

For continued certification, the organization conducts a new analysis, submits current results and documentation, and undergoes a new review by the FPI Screening Board.

The certification level is determined from the current evidence. Where the current results no longer meet the requirements of the previous level, the organization is assigned to the level supported by the current evidence.

Monitoring and authorized use

Only organizations whose applications have been successfully reviewed and whose authorization remains valid may use the UNIVERSAL FAIR PAY CHECK® certification mark.

The certification mark may be used only:

by the certified organization or organizational entity;
at the certification level awarded;
for the certification period stated;
in the registered and authorized form.

The Regulations define the following measures where requirements are no longer fulfilled or the certification mark is misused:

a warning;
additional or special checks;
withdrawal of authorization to use the certification mark.

The organization concerned is heard before sanctions are applied. In urgent cases, FPI management may withdraw authorization with immediate effect, subject to confirmation by the FPI Screening Board within 30 days.

Both the certificate and the certification mark display the applicable certification period. Stakeholders can therefore identify the period for which certification has been awarded. Organizations that continue certification receive an updated certificate and certification mark for the new certification period.

Public register

The FPI publishes a public register of certified organizations. The register includes the certified organization, country or certification scope, first certification date, current validity period, certification level, published pay gap information where applicable, audited tool used, and analysis partner.

The public register enables stakeholders to verify the certification level awarded, the applicable certification period, the audited tool used for the analysis, and, where applicable, the analysis partner supporting the certification.

Transparency in the context of EmpCo

Directive (EU) 2024/825, commonly referred to as the Empowering Consumers for the Green Transition Directive or EmpCo, addresses the transparency and credibility of sustainability labels, including labels relating to social characteristics.

The public information listed below brings together the Regulations of Use, the current composition of the FPI Screening Board, the public register of certified organizations, the EU certification mark framework, and the certification mark registration. These sources explain the certification scope, access conditions, assessment, governance, monitoring, sanctions, and authorized use of the UNIVERSAL FAIR PAY CHECK®.

Sources and public information

Questions about the certification system

For questions regarding the certification scope, certification requirements, audit status of a tool or methodology, authorized use of the certification mark, or the certification process, please contact the FPI Fair Pay Innovation Lab.