The Equality Plan: the mandatory document almost no one wants to draft
Since March 2022, every Spanish company with 50 or more employees is legally required to have a negotiated, registered, and current Equality Plan. The governing rules — Royal Decree-Law 6/2019 and RD 901/2020 — are demanding: a generic template will not do. The plan must rest on a quantitative diagnosis of your real workforce, include measures with indicators and a timeline, and be accompanied by a sexual harassment protocol.
The result: tens of thousands of Spanish small and medium companies are legally bound to produce a technically complex 80-150 page document with no clear starting point. The traditional answer has been to hire an external consultancy for €4,000-€12,000. The new answer is to use AI to do it in hours, with the same legal rigor.
This guide explains exactly how.
Who is required and what's at stake
Companies required:
- Every company with 50 or more workers (the count includes permanent, temporary, fixed-term, and part-time employees)
- Smaller companies if their collective agreement requires it
- Smaller companies ordered by Labour Inspection
- Any company that opts in voluntarily
Penalties for non-compliance (LISOS arts. 7.13 and 8.17):
| Infraction | Minimum amount | Maximum amount |
|---|---|---|
| Serious | €751 | €7,500 |
| Very serious | €7,501 | €225,018 |
In addition: exclusion from public contracts and subsidies, public sanction notice, and a Labour Inspection mandate to produce the plan within a fixed deadline.
In 2025 the Spanish Labour Inspection intensified compliance checks and issued thousands of notices. The obligation is no longer theoretical; it is operational.
What the Equality Plan must contain under RD 901/2020
Royal Decree 901/2020 of October 13 requires the following mandatory sections:
1. Situation diagnosis
Quantitative and qualitative analysis by gender of:
- Selection and hiring processes
- Professional classification
- Training
- Promotion
- Working conditions (including pay audit)
- Joint exercise of work-life balance rights
- Female under-representation
- Pay
- Sexual and gender-based harassment prevention
2. Pay audit (RD 902/2020)
Specifically:
- Pay register by gender, professional group, role, and level
- Mean and median pay gap calculation
- Job evaluation
- Action plan if the gap exceeds 25%
3. Measures and indicators
Concrete actions across each area (hiring, training, promotion, pay, work-life balance, harassment), with:
- Quantitative monitoring indicators
- Person responsible for each measure
- Implementation timeline
- Allocated resources
4. Timeline, monitoring system, and committee
- Validity period (max 4 years)
- Joint monitoring committee
- Modification procedure
- Dispute resolution procedure
5. Sexual and gender-based harassment protocol
In line with Organic Law 3/2007 and Law 10/2022 on sexual freedom:
- Statement of principles
- Confidential complaint procedure
- Investigation and resolution
- Cautionary and disciplinary measures
6. REGCON registration
The final document, signed by the legal worker representation (or the negotiating committee) and the company, is registered in the Collective Agreements Register (REGCON) through the electronic portal of the Spanish Ministry of Labour.
Why use AI: the economic case
| Path | Average cost | Time | Risk |
|---|---|---|---|
| External consultancy | €4,000 - €12,000 | 2-6 months | Low (if good) |
| Blank-page in-house | €0 | 4-8 weeks of internal work | High (legal errors) |
| Downloaded template | €0 - €200 | 2-4 weeks | Very high (not customized) |
| Specialized AI (Nomos) | €30 - €100 | Same day | Low (regulation-compliant) |
A consultancy charges for its drafting time. With AI, that time disappears: the document is generated from your real data in minutes. The internal team then handles the negotiation with worker representation — the only step the law forbids you to delegate to a third party.
The step-by-step process with AI
Step 1: Gather your workforce data
Export from your HR system (A3, Sage, Holded, Personio, etc.):
- Personnel list with gender, hire date, professional category, group, base salary, complements, contract type, work schedule, department
- Last year's data on training, promotions, work-life leave, terminations, hires
Important: anonymize the data before uploading (no names or ID numbers). Employee codes are sufficient for the analysis.
Step 2: Upload the collective agreement and internal policies
- Your applicable collective agreement
- Internal policies (harassment, work-life balance, remote work, code of ethics)
- Best-practices manual if one exists
- Any prior plan, if available
Step 3: AI generates the diagnosis
With this data, the AI automatically calculates:
- Distribution by gender across each category
- Mean and median pay gap by professional group
- Promotion and training rates by gender
- Horizontal and vertical segregation analysis
- Work-life balance indicators
The diagnosis is the section where most errors creep in when done manually, because it requires cross-referencing many tables and maintaining coherence across all of them. The AI does this in seconds with zero arithmetic errors.
Step 4: Measures tailored to your sector and diagnosis
From the diagnosis, the AI proposes concrete measures with:
- Quantitative monitoring indicators
- Realistic implementation timeline (typically 12-36 months)
- Estimated resources
- Responsible parties
You review, adjust, and remove anything that doesn't apply to your reality.
Step 5: Harassment protocol
A template adapted to RD 901/2020 and Law 10/2022. It includes:
- Complaint procedure (with a designated investigator)
- Investigation timeline
- Cautionary measures
- Disciplinary regime
Step 6: Negotiation with worker representation
This step cannot be delegated to AI or to a consultancy. The law requires good-faith negotiation with the legal worker representation (or, if none exists, with a negotiating committee formed by the most representative trade unions).
With the document already drafted, meetings focus on negotiating content — not on writing from scratch.
Step 7: Signature and REGCON registration
Once signed by both parties, the plan is registered at REGCON through the Ministry of Labour's electronic portal. Registration is mandatory for the plan to have legal effect.
Common mistakes (that AI avoids)
Mistake 1: Diagnosis without pay audit RD 902/2020 requires a specific pay audit. Many small companies omit it.
Mistake 2: Measures without quantitative indicators "Promote equality in promotions" is not a measure; it is a statement. The law requires verifiable numerical indicators.
Mistake 3: Generic harassment protocol copied from the internet Generic protocols don't adapt the procedure to the company's actual structure. This invalidates them in case of an actual complaint.
Mistake 4: Undocumented negotiation The signature with worker representation must be recorded in formal minutes. Without those minutes, REGCON may reject the registration.
Mistake 5: Rigid plan with no modification procedure The law requires the plan to specify how it can be modified if circumstances change. Without that procedure, future modifications require starting from scratch.
Realistic timelines
| Phase | Manual | With AI |
|---|---|---|
| Data collection | 2 weeks | 1 day |
| Diagnosis | 3 weeks | 30 minutes |
| Plan drafting | 4 weeks | 2 hours |
| Harassment protocol | 1 week | 10 minutes |
| Internal review | 1 week | 1 week |
| Negotiation with worker rep | 4-8 weeks | 4-8 weeks |
| REGCON registration | 1 week | 1 week |
| Total | 4-6 months | 6-10 weeks |
Negotiation with worker representation cannot be accelerated by AI — and rightly so. What is accelerated is all the prior drafting and analytical work.
Conclusion
The Spanish Equality Plan is one of the clearest opportunities to apply AI to a concrete and mandatory labour-compliance problem. The regulation is demanding; the penalty for non-compliance is costly; and the traditional consultancy market is expensive and slow.
With AI, a small or medium company can move from no Equality Plan to one registered in REGCON in 6-10 weeks, spending less than €100 on tools and fully complying with RD 901/2020. The one thing that cannot be delegated — negotiation with worker representation — remains internal work. The rest, today, is machine work.