Compliance guide
Compensation · Compliance
A Guide to the EU Pay Transparency Directive
What every EU employer actually needs to know: the six requirements, the reporting thresholds, and where the law stands country by country.
Correct as of July 2026
7 Jun '26
Transposition deadline (now passed)
7 Jun '27
First pay gap reports due (150+ headcount)
5%
Unjustified gap that triggers a pay assessment
All sizes
Recruitment rules apply to every employer
01 · The law
Six requirements, in order.
The Directive builds a full system: transparency before you're hired, transparency while you work, and enforcement if the numbers don't add up.
- 1
Pay transparency in recruitment
The pay range has to appear in the job ad, or be shared before the interview. Employers can no longer ask what you currently earn, or what you used to earn.
- 2
Workers' right to pay information
Any worker can request their own pay level, plus the average pay by gender for people doing equal-value work. The employer has to answer within two months.
- 3
Gender-neutral pay structures
Pay has to be set on objective criteria (skills, effort, responsibility, working conditions) inside a real job architecture. Without this, nothing else in the Directive is actually possible to demonstrate.
- 4
Gender pay gap reporting
Employers above the headcount threshold report the mean and median gap, the gap in variable pay, the gender split by pay quartile, and the gap by job category.
- 5
The 5% rule
An unexplained gap of 5% or more in any category, left uncorrected for six months, forces a joint pay assessment with worker representatives and a remedy plan.
- 6
Remedies and enforcement
The burden of proof shifts to the employer. Compensation is uncapped. Every member state has to legislate real, dissuasive penalties.
02 · The numbers
Thresholds and the state of play.
Gender pay gap reporting is headcount-gated. Everything else in the Directive (recruitment disclosure, the right to pay information) applies to every employer, regardless of size.
Gender pay gap reporting schedule
| EU headcount | Frequency | First report |
|---|---|---|
| Under 100 | Not required by the Directive* | n/a |
| 100–149 | Every 3 years | 2031 |
| 150–249 | Every 3 years | 2027 |
| 250+ | Annually | 2027 |
In force
Italy, Slovakia, Lithuania, Malta
Partially in force
Poland, Czechia, Belgium
Delayed, dated
France, Netherlands, Denmark, Finland, Spain & others (mostly targeting Jan 2027)
No draft yet
Germany, Austria, Portugal, Luxembourg & others
03 · Your move
What to do now.
Two things have no dependencies, so start them today. Everything else follows an order: job architecture unlocks pay bands, and pay bands are what make the gap analysis and worker requests actually answerable.
Start today, in parallel
Start now
Fix recruitment now
Add pay ranges to ads, drop salary-history questions. No deadline to wait for.
Start now
Document everything
Every pay decision needs a traceable, defensible reason. Build the habit before you need it.
Then, in this order
Step 1
Build a job architecture
2–4 months. Everything below depends on this being in place first.
Step 2
Define pay bands & criteria
Document objective, gender-neutral rules for how pay is set, using the architecture from step 1.
Step 3
Run a pay gap analysis
A topline number is possible anytime, but a proper category-by-category check needs the bands from step 2.
Step 4
Set up a request process
Once bands exist, you can actually give workers a defensible answer within the two-month window.
This is a readiness guide, not legal advice. Directive (EU) 2023/970 sets EU-wide minimums; each member state transposes it into its own national law, on its own timeline, sometimes with stricter rules. *Some countries set a lower reporting threshold than 100 (e.g. Ireland, at 50+). Country status is correct as of July 2026 and changes roughly monthly, so check your national legislation before acting.
Interactive diagnostic
Check where you stand
Answer five questions about headcount, countries, and current pay practices. Get a country-tagged readiness summary and prioritised next moves.
How ready are you? Try our diagnosticMore open resources
Other free templates and diagnostics from Open Org.
EU Pay Transparency Directive Diagnostic
Five-question readiness check: headcount, countries, gaps, and prioritised next moves.
Compensation Philosophy Template
Document how you pay people before you open ranges and reports.
Open Culture Framework
Score how open you are on pay and related transparency areas.
Open Org guide to the EU Pay Transparency Directive. Not legal advice. Adapt for your organisation.