Pay Transparency: first gender pay gap report due for employers with 150+ employees
Date note: Transposition deadline was 2026-06-07; many Member States (incl. Latvia, Poland, Germany, France) were late, so national dates may shift slightly. Employers with 100-149 staff report first by 2031-06-07
What changes
Directive (EU) 2023/970 requires employers to publish pay ranges before job interviews, stop asking candidates about salary history, give workers the right to ask about average pay by category, and – for employers with 150 or more staff – report gender pay gap figures for 2026 by June 2027 (250+ annually, 150-249 every three years). Gaps above 5% without objective justification trigger a joint pay assessment.
Who is affected
All employers for the transparency rights; medium and large employers with 100+ workers for pay-gap reporting.
Sizes: medium, large · Sectors: All sectors · Applies if: We employ staff
What to do
Set up objective, gender-neutral job categories and pay bands. Add pay ranges to job ads or provide them before interviews and remove salary-history questions. Employers with 150+ staff: prepare 2026 payroll data by gender and category for the June 2027 report and check the national law of your country for the exact reporting format.
Penalty
Set nationally; includes fines and compensation claims with reversed burden of proof
Sources
- European Commission – EU action for equal pay (Pay Transparency Directive) (commission.europa.eu)
- Morgan Lewis – Pay Transparency Directive: deadline for transposition has passed (www.morganlewis.com)
- Ius Laboris – which countries have transposed (iuslaboris.com)
Last verified 7 September 2026. Informational only, not legal advice.