Yes, you can in principle draw up a remuneration policy yourself. There is no legal requirement that the document be written or approved by an external party. What matters is the content: the pay transparency rules expect your policy to describe on the basis of which objective, gender-neutral criteria jobs are classified and remunerated, and that those criteria align with the job classification you have already made or still need to make.
The practical limit is thus not at "am I allowed to do it myself", but at "does the policy have the substantiation needed should someone ask for it". An employee making an information request, a report from one hundred workers or more, or a regulator does not look at the intention behind the document but at what it contains. You can write it yourself; determining for yourself which criteria are objective and gender-neutral is another matter.
What a remuneration policy means under these rules
A remuneration policy is more than an internal document with salary scales. It describes how jobs are valued, which factors count in determining remuneration (think of responsibility, required skills, working conditions) and how those factors are applied without distinction on grounds of sex. The policy must also align with the job classification: if two jobs are considered equivalent but are structurally remunerated differently, the policy must make clear what objective reason underlies this. More about how that classification into categories of equal work works can be found in the knowledge base on job classification and remuneration criteria.
What you can do yourself
Many elements are perfectly fine to handle internally. You can yourself map which remuneration components your organisation has (base salary, allowances, bonuses, secondary benefits), yourself record how job evaluation currently takes place, and yourself put a first version of the policy on paper. For a small organisation with a straightforward job structure, that is often manageable without external help. Where things often go wrong is not in the writing itself, but in checking whether the chosen criteria are truly gender-neutral and whether they are applied consistently across departments.
Where most organisations get stuck
Three points come up repeatedly. First: criteria that look neutral on paper but in practice favour one group, for instance physical strain as a weighty criterion in jobs that are performed almost exclusively by men. Second: a remuneration policy that stands apart from the actual job classification, so that the document does not match actual practice when an information request or report is made. Third: no documented substantiation for remuneration differences between equivalent jobs, whereas that substantiation is precisely what is asked for. None of these points necessarily requires external help, but they do require that someone looks critically at their own criteria before the policy is adopted.
When structure delivers more than time savings
The reason organisations from a certain size onwards nonetheless opt for a structured approach is rarely the writing work itself. It is the link between elements: the job classification must align with the remuneration policy, the remuneration policy must align with what is communicated in the job advertisement, and at one hundred workers or more everything must be traceable to a report. A separate document that looks correct in itself can still show inconsistencies in that aggregate. How payria.eu links those elements together, including the source of each data point, is described on the page about how the system is structured.
Start on your own, continue with structure
For those who want to see where their own organization stands before investing time in a policy document, an initial orientation at no cost is possible: the compliance check shows which obligations apply now and which only apply at a larger workforce size. What a job classification and the associated remuneration policy with support cost is stated on the page with pricing for the paid system.
Setting up remuneration policy yourself is therefore not a matter of being allowed or not allowed, but of knowing what substantiation will be needed later. Payria.eu does not judge whether a difference is justified and does not process wages; it structures the criteria and documents so you have them ready. If you want to first check what applies to your organization, do the free quick scan in a few questions or read the background in the knowledge base.