The EU Pay Transparency Directive (Directive (EU) 2023/970) requires employers to publish pay ranges to job applicants, stop asking about salary history, give workers the right to know average pay levels for comparable roles, and report their gender pay gap. Member states had to write it into national law by 7 June 2026. The first gender pay gap reports are due by 7 June 2027, covering 2026 data, so the payroll data being generated now is what employers will have to report.
This is the most significant pay equity legislation in Europe in decades, and it applies to any employer with workers in the EU, including companies headquartered elsewhere. This guide explains what the directive requires, who it applies to, the deadlines, and what employers should be doing now.
Adopted in May 2023, Directive (EU) 2023/970 strengthens the principle of equal pay for equal work, or work of equal value, between men and women. It does so through transparency: making pay information available to candidates, employees and regulators, and requiring employers to explain and address unjustified gaps.
As a directive, it sets minimum standards that each member state must write into national law. Some countries have gone further than the minimum, so employers need to check the rules in each country where they employ people.
The directive applies to employers with workers in the EU even if the company is based elsewhere, so US, UK and other non-EU companies with EU employees are in scope.
Employers must report gender pay gap data including mean and median gaps in base pay and in variable or complementary pay, the proportion of men and women receiving variable pay, and the distribution of men and women across pay quartiles.
| Employer size | First report due | Frequency |
|---|---|---|
| 250 or more workers | 7 June 2027 (2026 data) | Annually |
| 150 to 249 workers | 7 June 2027 (2026 data) | Every three years |
| 100 to 149 workers | 7 June 2031 | Every three years |
| Fewer than 100 workers | Not required by the directive | Some member states may extend it |
Because the first reports cover 2026 payroll data, employers in scope need accurate, structured pay data for the current year, including variable pay such as bonuses, overtime and allowances.
If reporting shows a gender pay gap of at least 5% in any category of workers that the employer cannot justify with objective, gender-neutral criteria, and the employer does not remedy it within six months of submitting its pay report, the employer must carry out a joint pay assessment (Article 10) with worker representatives. That assessment analyses the causes of the gap and sets out measures to address it.
The transposition deadline was 7 June 2026, but most member states missed it. At 12 October 2026, four had a full transposing law in force: Italy, Lithuania, Malta and Slovakia. Greece became the fifth when the main obligations of its law (Law 5316/2026) applied from 1 November 2026. Estonia has implemented parts of the directive, and most other member states are still at the draft or bill stage (Deloitte Legal, October 2026).
Chart: EU transposition status, November 2026
Number of EU member states by stage of transposing Directive (EU) 2023/970. Scale: 0 to 27 member states.
Full law in force: Italy, Lithuania, Malta, Slovakia, and Greece (main obligations from 1 November 2026). Status as at 12 October 2026, updated for Greece. Source: Deloitte Legal, EU Pay Transparency Directive transposition update.
For employers, this creates a tricky position: the obligations are coming everywhere, but the detail, timing and penalties differ by country. Waiting for each national law before preparing leaves very little time to get pay data in order.
Member states had to transpose it into national law by 7 June 2026. Most missed the deadline, so national laws are taking effect at different points during 2026 and 2027.
You must provide the starting salary or pay range either in the job advert or before the interview. Some national laws may be stricter.
No. The directive prohibits asking candidates about their current or previous pay.
Employers with 100 or more workers, phased by size: 250 or more report annually from June 2027, 150 to 249 every three years from June 2027, and 100 to 149 every three years from June 2031.
If a gap of 5% or more in a category of workers cannot be objectively justified and is not remedied within six months, the employer must conduct a joint pay assessment with worker representatives and take corrective action.
Yes, where they employ workers in the EU. The obligations follow the employment relationship, not the company's headquarters.
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