EU directive

EU Pay Transparency Directive

The EU Pay Transparency Directive sets a new standard for how employers work with pay equity and transparency across Europe. At the same time, national processes have recently evolved in several countries, which means timelines and implementation may vary.

For employers, this does not reduce the importance of the topic – it makes it more important to understand what is coming and how to prepare in a structured way.

Here, we guide you through what the directive means, what to expect, and how your organisation can prepare.

Map of Europe drawn as a grid of pay squares

What is the EU Pay Transparency Directive?

The EU Pay Transparency Directive (2023/970), adopted on 10 May 2023, is designed to strengthen the principle of equal pay for equal work or work of equal value between men and women. It introduces measures to increase transparency, improve reporting, and strengthen enforcement across the EU.

For employers, the Directive signals a clear shift towards greater transparency in how pay is set and communicated. This includes providing pay information earlier in the hiring process, increasing visibility into pay levels, and preparing for potential reporting requirements. In some cases, organisations may also need to address unexplained pay gaps and strengthen their internal processes.

Member States had until 7 June 2026 to transpose the Directive into national law. The first gender pay gap reports are due by 7 June 2027, for employers with 150 or more employees.

Pay structures based on gender-neutral criteria

Employers must have pay structures that ensure equal pay for equal work and for work of equal value. Which roles count as work of equal value is decided with objective, gender-neutral criteria.

The Directive names four criteria that must be part of that assessment:

  • Skills: education, training and experience the role requires
  • Effort: the physical and mental demands of the role
  • Responsibility: for people, results, budgets or safety
  • Working conditions: the environment the work is done in

Employers must also make the criteria used to set pay, pay levels and pay progression easily available to employees. Member States may exempt employers with fewer than 50 employees from the part about pay progression.

A structured job evaluation is the most common way to group roles of equal value and show that the grouping is gender-neutral.

Pay transparency in recruitment

The Directive changes how employers talk about pay before someone is hired.

  • Job applicants have the right to information about the starting pay, or its range, for the role. It must be given in the job ad or before the interview, based on objective, gender-neutral criteria.
  • Employers may not ask applicants about their current or previous pay.
  • Job titles and job ads must be gender-neutral, and recruitment must be non-discriminatory.

In several countries these rules are among the first to apply. Poland and Estonia, for example, introduced the recruitment rules before the rest of the Directive.

Gender pay gap reporting: who, when and what

Employers with 100 or more employees must report on the gender pay gap. How often depends on the size of the organisation. The dates below are the Directive's; national law may set earlier dates or lower thresholds.

Gender pay gap reporting under the EU Pay Transparency Directive: who reports, how often and when
EmployeesHow oftenFirst report
250 or moreEvery year7 June 2027 (for 2026)
150–249Every three years7 June 2027
100–149Every three years7 June 2031
Fewer than 100Voluntary, unless national law says otherwise–

What the report must include

The report covers seven indicators. The first six are shared with the national monitoring body and can be made public. The last one, the gap by category of workers, is shared with employees, their representatives and the labour inspectorate.

  1. The gender pay gap (mean)
  2. The gender pay gap in complementary or variable pay (mean)
  3. The median gender pay gap
  4. The median gender pay gap in complementary or variable pay
  5. The share of women and men who receive complementary or variable pay
  6. The share of women and men in each pay quartile
  7. The gender pay gap by category of workers doing equal work or work of equal value, split by basic pay and complementary or variable pay

All seven indicators come out of a structured pay audit, which is why most employers start there.

When is a joint pay assessment required?

A joint pay assessment is a deeper review that the employer carries out together with employee representatives. It is required when all three of these apply:

  • The report shows a gender pay gap of at least 5% in any category of workers
  • The employer cannot justify the gap with objective, gender-neutral criteria
  • The employer has not corrected the gap within six months of the report

What the assessment covers

The assessment looks at the share of women and men in each category of workers, their average pay and pay gaps, and the reasons for any differences. It also covers the share of employees who got a pay rise after returning from parental leave, the measures to close unjustified gaps, and how well earlier measures worked.

The simplest way to avoid one is to explain or close gaps before the report is due. Pay audit software can flag unexplained gaps as soon as the data is in.

Potential sanctions for non-compliance

Burden of proof may fall on the employer

In disputes regarding unequal pay, employers may need to demonstrate that pay practices are non-discriminatory and based on objective criteria.

Risk of collective claims

The Directive strengthens enforcement and may increase the risk of collective claims related to discriminatory pay practices.

Free checklist: prepare for the Directive

The EU Pay Transparency Directive introduces increased requirements for pay transparency and reporting.

With our free checklist, you'll get clear, practical steps to prepare your organisation in a structured way and stay ahead of upcoming requirements.

The checklist helps you to:

  • Identify key actions
  • Prepare for upcoming requirements
  • Build a more transparent and structured pay process

Download the checklist and get a clear starting point for your preparations.

Country updates

The Directive, country by country

All articles on the directive
Greece implements the EU Pay Transparency Directive
EU Transparency Directive
4 min read

Greece implements the EU Pay Transparency Directive

Greece has now implemented the EU Pay Transparency Directive through Law 5316/2026, becoming the fifth EU Member State to complete the transposition process. The Greek Parliament adopted the law on 2 July 2026, and it was published in the Government Gazette on 6 July 2026.

Read more
Italy implements the EU Pay Transparency Directive
EU Transparency Directive
3 min read

Italy implements the EU Pay Transparency Directive

Italy has now formally implemented the EU Pay Transparency Directive through Legislative Decree No. 96/2026. The decree was published in the Official Gazette on 1 June 2026 and entered into force on 7 June 2026.

Read more

Key definitions

Gender pay gap

The difference in average pay between women and men, expressed as a percentage of men's average pay.

Unexplained gender pay gap

The portion of the pay gap that cannot be explained by objective, gender-neutral factors such as role, experience, or location.

Median pay

The midpoint in the pay distribution: where half of employees earn more and half earn less.

Work of equal value

Work that is considered comparable based on objective, gender-neutral criteria such as skills, responsibility, effort, and working conditions.

Why start preparing for the Directive now

The EU Pay Transparency Directive sets a clear direction toward greater transparency, even as national timelines and requirements continue to evolve.

Starting preparations early allows organizations to build the right foundations for pay structures, data quality, and reporting, regardless of exact timing.

Early action reduces risk, strengthens internal consistency, and creates better conditions for transparent and fair pay practices. It also gives you time to identify and address potential pay gaps, a process that is often more complex than expected.

In short: this is not just about compliance, but about building sustainable and fair pay structures over time.

Automated pay transparency software for the Directive

Pay structures built on work of equal value

Pihr Evaluation groups every role with a gender-neutral method based on skills, effort, responsibility and working conditions, the criteria the Directive requires.

Automated pay gap reports

Upload your payroll file and Pihr's pay transparency software calculates the indicators the law requires, adapted to each country's rules, with one report for every market.

Right to information in days, not weeks

When an employee asks how their pay compares, Pihr generates the answer from your latest pay audit, ready to send.

Every gap explained or closed

Pihr explains most differences automatically, lists the rest and shows what it costs to close them, before they lead to a joint pay assessment.

Magnus Drogell
Most employers already have what the Directive asks for: their pay data. We help them turn it into a pay structure they can explain, long before the first report is due.
Magnus DrogellFounder & Pay Transparency Expert, Pihr

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FAQ: EU Pay Transparency Directive

When does the Directive take effect?

The Directive entered into force in June 2023, and Member States had until 7 June 2026 to transpose it into national law. Several countries have not yet done so, so when the rules apply to you depends on where you have employees. The first gender pay gap reports are due by 7 June 2027.

Which employers are affected?

All employers operating in the EU are within scope. Specific obligations, thresholds, and timelines depend on national implementation and often on company size.

Do we need to show pay ranges in job ads?

Employers are expected to provide information about the initial pay level or range for a role, either in the job ad or before the first interview. Employers should also not ask about a candidate's salary history.

What information can employees request?

Employees can request written information about their individual pay and average pay levels, broken down by gender, for comparable roles or work of equal value.

What counts as “work of equal value”?

Roles are compared using objective, gender-neutral criteria such as skills, responsibility, effort, and working conditions, typically supported by a structured job architecture.

Will we need to report gender pay gaps?

Yes, if you have 100 or more employees. Employers with 250 or more report every year and those with 150–249 every three years, both from 7 June 2027. Employers with 100–149 report every three years from 7 June 2031. National law can set earlier dates or lower thresholds.

What is a joint pay assessment (JPA)?

If a gender pay gap of at least 5% in any category of workers cannot be justified by objective, gender-neutral factors and is not corrected within six months, employers must carry out a joint pay assessment with employee representatives and define corrective actions.

What data should we prepare?

A structured employee dataset (base and variable pay, FTE, allowances), job architecture, comparable-role groupings, and a clear methodology for analysing pay gaps.

What are the risks of non-compliance?

Penalties are defined nationally but may include fines, compensation, and procedural changes such as a shift in burden of proof in discrimination cases.

How should we get started?

Start by reviewing your pay structure, aligning job architecture, defining pay bands, and running a baseline analysis of pay gaps. Early preparation makes future compliance significantly easier.