How often do employers have to report under the Pay Transparency Directive?

Employers with 250 or more workers report annually. Employers with 100-249 workers report every three years. Employers under 100 workers have no EU-level reporting obligation, though member states may set stricter national rules.

What was the transposition deadline for the directive?

EU member states were required to transpose Directive (EU) 2023/970 into national law by 7 June 2026. Many states missed this deadline, so national implementing law -- not the directive text alone -- ultimately governs the exact obligations in each country.

What data goes into a pay gap report?

Article 9 sets out metrics including the gender pay gap, the gap in complementary or variable pay, the median gender pay gap, the proportion of women and men receiving complementary pay, the pay gap by quartile pay band, and the proportion of workers in each gender receiving no complementary pay.

EU Pay Transparency Directive reporting deadlines: 2027 and 2031

Q: When is the first EU Pay Transparency Directive report due?

Employers with 150 or more workers must submit their first gender pay gap report by 7 June 2027, covering the 2026 reference year. Employers with 100-149 workers have their first report due by 7 June 2031.

Q: What is the 5% pay gap rule?

Under Article 10, if reporting shows an unexplained gender pay gap of 5% or more in any category of workers doing the same work or work of equal value, and the employer cannot justify it on objective, gender-neutral criteria, the employer must carry out a joint pay assessment with worker representatives within six months.

Last reviewed 17 July 2026. Reflects Directive (EU) 2023/970. National transposition law governs the exact obligations in each member state -- verify against your country's implementing legislation.

What the directive requires

Directive (EU) 2023/970 on pay transparency requires employers above certain size thresholds to report gender pay gap data to a designated national authority and, in most cases, to make parts of it available to workers and their representatives. It also gives job applicants a right to pay information before interviews and bans asking candidates about their pay history.

The obligation this guide focuses on is reporting: which employers must report, on what schedule, and what triggers deeper action when the numbers show an unexplained gap.

In one sentence: employer size decides both when your first report is due and how often you report afterwards -- 250+ workers report annually starting 2027, 150-249 report every three years starting 2027, and 100-149 report every three years starting 2031.

Transposition vs. reporting dates

Two different dates matter here, and they are often confused.

Transposition deadline	7 June 2026 -- the date by which EU member states had to write the directive into national law. Many states missed it, so check your own country's implementing legislation for the exact domestic rules.
First reporting deadline	7 June 2027 for the largest employers (see size bands below) -- the date by which the first gender pay gap report is due to the competent national authority.

Because transposition was uneven across the EU, the directive's text is the reliable baseline, but your obligations in practice run through whatever your national law says -- including which authority you report to and in what format.

The size bands and the 2027/2031 timeline

The first reporting deadline depends on how many workers the employer has:

250+ workers	First report due 7 June 2027, covering reference year 2026. Reports annually thereafter.
150-249 workers	First report due 7 June 2027. Reports every three years thereafter.
100-149 workers	First report due 7 June 2031. Reports every three years thereafter.
Under 100 workers	No EU-level reporting obligation. Member states may impose stricter national requirements.

The reference year for a report is the calendar year before it is due -- so the 2027 reports cover 2026 pay data.

Annual vs. every-three-years

Reporting frequency is not the same for every size band that reports by 2027. Employers with 250 or more workers report every year. Employers with 100-249 workers -- whether their first report lands in 2027 or 2031 -- report every three years, not annually.

A 200-worker employer and a 300-worker employer can share the same first reporting year but end up on completely different cycles afterwards: three-yearly for the smaller one, annual for the larger one.

The 5% joint pay assessment trigger

Article 10 adds a consequence for employers whose own reported numbers look bad. If a report shows a gender pay gap of 5% or more in any category of workers performing the same work or work of equal value, and the employer cannot justify the gap using objective, gender-neutral criteria, the employer must carry out a joint pay assessment with worker representatives.

The assessment must begin promptly and is expected to lead to remedial measures; employers are generally expected to act within six months of identifying an unjustified gap. The trigger applies per category of workers, not just to the organisation-wide average -- so a healthy overall figure does not protect against a flagged category underneath it.

The Article 9 metrics

A compliant report is not just one number. Article 9 lists several metrics employers must calculate and disclose, including:

The mean and median gender pay gap
The mean and median gap in complementary or variable pay
The proportion of women and men receiving complementary or variable pay
The proportion of women and men in each quartile pay band
The gender pay gap broken down by category of workers doing the same work or work of equal value

Common misconceptions

"Every employer reports every year." No. Only the 250+ band reports annually. Everyone else reporting under the directive does so every three years.
"The transposition deadline is when I have to report." No. 7 June 2026 was for member states to pass national law. The employer reporting deadlines are 2027 or 2031 depending on size.
"A good average pay gap means I'm safe." No. The 5% joint-assessment trigger applies per category of workers doing equal work, so an unjustified gap in one job category can trigger action even if the company-wide figure looks fine.
"Under 100 workers means no obligations at all." Not necessarily. There is no EU-level reporting duty below 100 workers, but national law in your member state may go further.

Building the report itself

Once you know your reporting date, the recurring job is calculating the Article 9 metrics correctly from payroll data. Pay Gap Report Studio computes the mean and median gap, complementary pay gaps, quartile bands and category breakdowns locally in your browser from a pasted or uploaded spreadsheet -- nothing is uploaded to a server.

Open Pay Gap Report Studio

Frequently asked questions

When is the first EU Pay Transparency Directive report due?

Employers with 150 or more workers must submit their first report by 7 June 2027, covering 2026 pay data. Employers with 100-149 workers have their first report due by 7 June 2031.

How often do employers have to report?

Employers with 250 or more workers report annually. Employers with 100-249 workers report every three years. There is no EU-level obligation below 100 workers.

What is the 5% pay gap rule?

If reporting shows an unexplained gender pay gap of 5% or more in any category of workers doing equal work, and the employer cannot justify it objectively, a joint pay assessment with worker representatives is required.

What was the transposition deadline?

Member states had until 7 June 2026 to transpose the directive into national law. Many missed this deadline; national implementing law governs the exact obligations in each country.

What data does a compliant report need?

Article 9 metrics including the mean and median gender pay gap, the gap in complementary pay, the proportion of each gender receiving complementary pay, and the pay gap by quartile band and worker category.

Sources

Directive (EU) 2023/970 on pay transparency, Official Journal — eur-lex.europa.eu
European Commission — EU action on equal pay / pay transparency — commission.europa.eu

This guide is general information about the EU Pay Transparency Directive, not legal or HR advice. Transposition into national law varies by member state and some details may differ from the directive text -- verify current dates, thresholds and procedures against the Official Journal, the European Commission, and your national implementing legislation before relying on any figure.