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Basic Module

B10: Workforce – remuneration, collective bargaining and training

Minimum wage, collective agreements, training hours and, where the law requires it, the gender pay gap.

In brief

B10 covers pay and training. You state whether all employees are paid at least the applicable minimum wage, the share of employees covered by collective bargaining agreements, and the average annual training hours per employee. The gender pay gap is required only if EU or national law already requires your company to report it. In practice, this follows the Pay Transparency Directive as each country transposes it into national law.

At a glance

Requirement
Essential: minimum wage, collective bargaining coverage and training. The gender pay gap if the law already requires you to report it.
10 employees or less
Required in full.
Value chain cap (from 2027)
Minimum wage, collective bargaining coverage and average training hours, for all sizes.
In Selko Report
Page "Workforce"

What changed from VSME

  • Changed: the gender pay gap is required only if EU law, such as the Pay Transparency Directive (EU) 2023/970, or national rules already require you to report it. VSME required it from 150 employees.
  • Changed: training is reported as one average per employee. VSME split training hours by gender.
  • Unchanged: minimum wage and collective bargaining coverage.

VS Standard Reference

The official text of the Voluntary Standard, Annex I to Commission Delegated Regulation (EU) 2026/1560.

Selko Insights

How Selko applies it

Paragraph 42(b)
Selko Report

Is the pay gap a legal requirement for you?

Selko Report asks: "Is the gender pay gap a legal requirement for you?" Until you answer, Selko suggests an answer from your company's own year-end headcount, country and year, and explains the rule that applies. The law binds each employer on its own headcount, not a group's total. Your answer always takes precedence. If the pay gap is not required, you can still report it voluntarily.

Pay Transparency Directive
Selko Report

The rules in Finland and Sweden

Finland's government bill HE 129/2026 was still before Parliament in October 2026. It is meant to take effect on 1 January 2027 and proposes pay gap reporting:

  • every year for employers with 250 or more employees, starting with calendar year 2027;
  • every third year for employers with 150–249 employees, starting with calendar year 2027;
  • every third year for employers with 100–149 employees, starting with calendar year 2030.

The first reports would be due in 2028 and 2031. Sweden has not yet transposed the directive. For other countries, check the national rules.

Calculation
Selko Report

How the pay gap is calculated

EFRAG's guidance uses the unadjusted pay gap: men's average gross hourly pay minus women's, divided by men's, as a percentage. It does not account for differences in roles, experience or working hours. In a small company, a few people in different roles can create a large gap that does not mean unequal pay for equal work. You can add context, as EFRAG's guidance suggests.

Paragraph 42(a)
Selko Report

Minimum wage without a statutory minimum

Finland and Sweden have no statutory minimum wage. The minimum wage is then the pay set by the collective agreement that applies in your sector, in Finland also a generally binding agreement. If someone earns less, answer No and give the reason.

Paragraph 42(c)
Selko Report

Collective bargaining coverage

Report the share of employees whose pay and working conditions are set by a collective agreement, including a generally binding agreement your company applies. Use the year-end headcount. If you do not know the exact share, you can report a range, as EFRAG's guidance allows.

Paragraph 42(d)
Selko Report

Training hours

Enter the total training hours your employees completed during the year: classroom, online and external training, including work-related training such as safety, qualifications and systems. Selko Report divides the total by the year-end headcount. EFRAG's guidance asks you to use headcount figures. If you have not tracked training hours before, a careful estimate is acceptable for the first year. Set up tracking for the next one.

Frequently asked questions

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