EU pay transparency directive: what employers report
Rules last read on 5 November 2026.
Directive (EU) 2023/970 had to become national law by 7 June 2026. The duty on an employer comes from its country's law, which may add to the directive or differ from it. The calculator gives the directive's own seven indicators, not a national filing format.
Who reports, and when (Art. 9)
| Workers | First report | Then | Data |
|---|---|---|---|
| 250 or more | 7 June 2027 | Every year | Calendar 2026 |
| 150 to 249 | 7 June 2027 | Every 3 years | Calendar 2026 |
| 100 to 149 | 7 June 2031 | Every 3 years | Calendar 2030 |
| Under 100 | Voluntary |
The seven indicators (Art. 9(1))
- The gender pay gap.
- The gap in complementary or variable components.
- The median gender pay gap.
- The median gap in complementary or variable components.
- The share of women and of men receiving complementary or variable components.
- The share of women and of men in each quartile pay band.
- The gap by category of workers, split into ordinary basic pay and complementary or variable components.
Pay level means gross annual pay and the corresponding gross hourly pay (Art. 3(1)), so each gap comes twice. A gap is the difference between men's and women's level as a percentage of men's. Variable pay is an open list in recital 21: bonuses, overtime, allowances and more.
Management confirms the figures are accurate after consulting workers' representatives, who may see the methods (Art. 9(6)). Where a state compiles figures itself it can do so for (a) to (f) only: (g) stays with the employer, who gives it to workers and their representatives (Art. 9(8), (9)). The monitoring body publishes (a) to (f) so employers can be compared (Art. 29).
The 5% check (Art. 10)
A joint pay assessment follows where a report shows a difference of at least 5% in average pay in a category, the employer has not justified it on objective, gender-neutral criteria, and has not remedied it within six months. The calculator marks categories at 5% or more. Whether a gap is justified is for you and your representatives.
Where national law stands
| State | Law | What differs |
|---|---|---|
| Italy | D.Lgs. 96/2026 | A ministry decree is to set collection, including data INPS, INAIL and the inspectorate hold. We found none published, so no format is known. |
| Slovakia | Act 76/2026 | First report by 7 June 2027 covers 1 August to 31 December 2026 only. Later reports by 15 April. |
| Malta | L.N. 173 of 2026 | By 7 June 2027, and also a 14-working-day rule after the year end. How the two fit is unclear from the text. |
| Spain | RD 902/2020 | Pay register in force. Draft decree for the directive, not law when last read. |
| Netherlands | Bill 36 949 | A bill: first report for 150 or more on 7 June 2028, on 2027. |
| France | Bill no. 944 | A bill: current index in 2027, new indicators from 2028. |
| Germany | Entgelttransparenzgesetz 2017 | We found no bill for the directive, so we give no German date. |
Italy, Slovakia and Malta were read in their own official texts. The others come from official bill pages or secondary sources, and they change: check your own country before you rely on this table. Slovak and Maltese report formats were not found.