Are you already testing the 5% joint assessment trigger per category, or waiting?

Packaging group, about 2,800 employees across Germany, the Netherlands and Spain. Reading the directive, a gap of 5% or more in any category of workers that is not justified and not corrected within six months leads to a joint pay assessment with employee representatives.

I ran a dry run on last year's data using our 23 provisional categories. Nine of them show a gap above 5% before any justification, in both directions: six where women are paid less and three where men are. In several the category has fewer than 20 people.

Are others running this test already, and how are you documenting the justification for categories that breach? I am particularly unsure how much weight seniority can carry.