Is AFAS enough for EU pay transparency compliance?
AFAS supports administration, but organizations still need job architecture, objective job evaluation, and pay gap analysis.
Many organisations using AFAS wonder whether their HR system prepares them for the EU Pay Transparency Directive. AFAS provides a strong foundation for payroll administration. At the same time, the directive requires steps that go beyond the scope of an HR system. In this article, we map out what AFAS covers, what the directive additionally requires and how Payqual can help.
Last update: March 20, 2026 · Reading time: 8 minutes
The EU Pay Transparency Directive (2023/970) must be transposed into Dutch law by June 2026. The law affects every employer: from objective job classification and salary indications in vacancies to periodic pay gap reporting and the right to pay information for employees. AFAS has announced support for some of these obligations in their HR module. In addition, there are elements of the directive that require specialised tooling.
This article is intended for HR professionals and executives who use AFAS and want to know how best to prepare for pay transparency legislation. We outline what AFAS offers and what the law additionally requires.
AFAS has taken steps to support pay transparency. These are the key features.
AFAS provides a table field for functions where you can record job categories. This is the basis for grouping functions for statutory reporting.
For compensation components, AFAS aligns with LoonLBPH (payroll tax) concepts, making salary data available in a structured format.
AFAS supports displaying salary indications for vacancies, as the directive requires for the recruitment process.
The EU Pay Transparency Directive requires more than payroll administration. On two points, additional tooling is needed.
AFAS provides a table field for recording job categories. The substantive classification — determining which functions are equivalent — is the employer's responsibility. The law requires this classification to be objective and gender-neutral, based on skills, effort, responsibilities and working conditions. This is the legal crux of the directive and requires a structured methodology.
AFAS makes salary data available, but doesn't offer tooling to flag unexplained pay gaps. If an employer has a pay gap of 5% or more that cannot be objectively explained, a Joint Pay Assessment is mandatory. This analysis and follow-up process require specialised software.
How does AFAS compare to Payqual on the key elements of the EU Pay Transparency Directive?
Salary processing, payslips and integration with payroll tax concepts
Displaying salary ranges to applicants, as required by the directive
Table field for manual classification; Payqual additionally clusters based on objective criteria
Gender-neutral classification based on skills, effort, responsibilities and working conditions
Automatically flagging unexplained pay gaps and initiating Joint Pay Assessment
Generating pay information request responses with comparison data per cluster
Importing data from multiple HR systems and analysing across systems
Full documentation of classification method, decisions and corrections
Closed chain from data import via analysis to statutory report
Payqual is built to cover the compliance steps that go beyond the scope of HR systems like AFAS.
Many organisations work with multiple HR systems due to acquisitions, international entities, or a flexible workforce via a different system. Payqual imports data from any HR system — including AFAS — and analyses across those systems.
The right to pay information applies to all employers and requires immediate readiness. Payqual can already generate a Pay Information Request (PIR) based on the ICRA analysis, so you can immediately comply with employee requests.
Where AFAS provides the data, Payqual offers a closed workflow from data import to report, where every step is legally substantiated. Together they form a chain from payroll administration to audit-proof compliance.
Under the new law, the burden of proof lies with the employer. You need not only data, but must also demonstrate how you arrived at your classification, that the method is objective, and that deviations have been explained or corrected. Payqual documents every decision and delivers a complete audit trail.
You only need payroll administration, your organisation is small enough to classify functions manually, and you have your own methodology for objective job evaluation. AFAS is a solid HR system for daily payroll processing.
You want to comply with the full EU Pay Transparency Directive: objective job classification, automatic risk detection, PIR generation, reporting and an audit trail. Especially with 100+ employees or multiple HR systems, additional tooling is valuable.
AFAS and Payqual are not mutually exclusive. Payqual imports data from AFAS and adds the compliance layer. Together they cover the full chain from payroll administration to legal compliance.
AFAS supports administration, but organizations still need job architecture, objective job evaluation, and pay gap analysis.
You need extra tooling when you want evidence-based role comparisons and audit-ready reporting.
Yes. Payqual can be used alongside existing HR systems and adds compliance-specific workflows.
Schedule a demo and discover how Payqual turns your AFAS data into full pay transparency compliance.