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Directive (EU) 2023/970

Pay transparency: what your own country asks, and when

Who it applies to
Every employer in the EU, public or private. The reporting duty starts at 100 workers; the pay structure duties start at one.
The dates
The Directive's date for member states was 7 June 2026. 4 of 27 have transposed, so elsewhere no reporting duty has arrived yet.
The one thing to do
Build a pay structure on gender-neutral criteria, tell applicants the pay range, answer a worker's request within two months, and report when your own law asks.

The determination on its own page

What the four states that have transposed actually require

4 of 27 member states have notified an act that transposes this Directive, 12 have notified measures that are something else, and 11 have notified nothing. Three of the four ask for something the Directive does not.

The member states that have transposed Directive (EU) 2023/970, and what each one adds
GreeceΝόμος 5316/2026, ΦΕΚ Α' 105 of 6 July 2026Not read

The law and its gazette reference are certain; its text is not. Three official routes refuse an automated client, and the only reachable copy is a subscription publisher. A deadline nobody can open is worse than no deadline.

ItalyDecreto legislativo 7 maggio 2026, n. 967 June 2027
  • The reporting article applies only to employers with at least 100 employees (Article 9(8)), so below that there is no Italian reporting duty at all rather than a voluntary one.
  • An employer with a single group pay policy may report aggregated at national level where that represents the data more reliably (Article 9(3)).
  • The Ministry of Labour collects the data; the employer does not publish it. Article 9(4) leaves the mechanism to ministerial decrees, due within ninety days of 7 June 2026. They may take the data from INPS, INAIL and the labour inspectorate, so what an employer sends is set by them.
MaltaEqual Pay (Transparency and Reporting) Regulations, 2026 (L.N. 173 of 2026)7 June 2027
  • The first report covers calendar year 2026 for both reporting bands (regulation 9(2) and 9(3)). The pay data being collected this year is what that report is made from.
  • The second report for the 150 to 249 band covers 2029 and not 2028, which is what three-yearly means once the first period is fixed (regulation 9(3)).
  • Regulation 9(5) wants every report submitted within fourteen working days of the yearly period's end. That falls far earlier than the 7 June dates in the same regulation. Both are in the act; plan for the earlier one.
SlovakiaZákon č. 76/2026 Z. z.7 June 2027
  • Slovakia merges the Directive's two middle bands: one three-yearly duty for 100 to 249 employees, and an annual one at 250 and above (Section 14(2) and (3)).
  • The annual deadline is 15 April of the following calendar year, a month the Directive does not mention (Section 14(2)).
  • An employer with at least 150 employees reports first by 7 June 2027, for 1 August to 31 December 2026 only (Section 18(3)). One with 100 to 149 reports first by 7 June 2031, for 2030 (Section 18(4)).
  • An employer established before 7 June 2026 had to have its pay structure in place by 31 July 2026 (Section 18(1)). That date has passed, and no date in the Directive says so.
  • Below 100 employees a report may be provided and is not required (Section 14(4)).

Every member state

Four acts have been read in full; this is where each of the twenty-seven stands on the register.

Every member state
Member stateRegister
AustriaSomething else communicated
BelgiumSomething else communicated
BulgariaSomething else communicated
CroatiaNothing communicated
CyprusNothing communicated
CzechiaSomething else communicated
DenmarkNothing communicated
EstoniaSomething else communicated
FinlandNothing communicated
FranceNothing communicated
GermanyNothing communicated
GreeceTransposed
HungaryNothing communicated
IrelandNothing communicated
ItalyTransposed
LatviaSomething else communicated
LithuaniaSomething else communicated
LuxembourgNothing communicated
MaltaTransposed
NetherlandsNothing communicated
PolandSomething else communicated
PortugalNothing communicated
RomaniaSomething else communicated
SlovakiaTransposed
SloveniaSomething else communicated
SpainSomething else communicated
SwedenSomething else communicated

Whatever a state has done, the equal pay principle of Article 157 TFEU binds employers directly and needs no national law (Defrenne II, Case 43/75).

The duties underneath

60 rows, in the Directive's own order and under its own article headings.

Scope

  • 2(1)This Directive reaches every employer, public or private · every employer
  • 2(2)It covers everyone you employ under a contract or relationship · every employer
  • 2(3)For recruitment, it also covers your applicants · every employer

Equal work and work of equal value

  • 4(1)Build a pay structure that pays equal work equally · every employer
  • 4(2)Your state must provide a job evaluation tool · every employer
  • 4(3)The Commission may update the Union job evaluation guidelines · every employer
  • 4(4)Make the structure show when two jobs are equal · every employer

Pay transparency prior to employment

  • 5(1)Tell applicants the pay range before the interview · every employer
  • 5(2)Never ask an applicant what they earn now · every employer
  • 5(3)Keep vacancy notices and job titles gender-neutral · every employer

Transparency of pay setting and pay progression policy

  • 6(1)Publish the criteria you use to set pay and progression · every employer
  • 6(2)Under 50 workers, your state may drop the progression part · every employer

Right to information

  • 7(1)Answer a worker's written request for their pay comparison · every employer
  • 7(2)Accept the request through a representative or an equality body · every employer
  • 7(3)Tell every worker once a year that this right exists · every employer
  • 7(4)Reply within two months of the request · every employer
  • 7(5)Drop any clause that stops a worker discussing pay · every employer
  • 7(6)Limit the figures to the equal pay claim · every employer

Accessibility of information

  • 8Give the information in an accessible format · every employer

Reporting on pay gap between female and male workers

  • 9(1)Report the seven pay gap figures for your organisation · in a reporting band
  • 9(2)At 250 workers or more, report every year · in a reporting band
  • 9(3)At 150 to 249 workers, report every three years · in a reporting band
  • 9(4)At 100 to 149 workers, report from 2031 · in a reporting band
  • 9(5)Under 100 workers you may report, and your state may require it · every employer
  • 9(6)Have management confirm the figures after consulting representatives · in a reporting band
  • 9(7)Send the figures to the authority your state names · in a reporting band
  • 9(8)Your state may compile the figures from its own tax data · in a reporting band
  • 9(9)Give the category breakdown to every worker and representative · in a reporting band
  • 9(10)Explain any gap when a worker or inspector asks · in a reporting band

Joint pay assessment

  • 10(1)Run a joint pay assessment on an unexplained five percent gap · in a reporting band
  • 10(2)Cover all seven elements in the assessment · in a reporting band
  • 10(3)Share the assessment with workers and the monitoring body · in a reporting band
  • 10(4)Close the unjustified gap within a reasonable time · in a reporting band

Support for employers with fewer than 250 workers

  • 11Under 250 workers, your state owes you help and training · every employer

Data protection

  • 12(1)Handle the pay data under the GDPR · every employer
  • 12(2)Use the pay data for equal pay and nothing else · every employer
  • 12(3)Your state may route a single worker's pay to representatives only · every employer

Shift of burden of proof

  • 18(1)In a claim, you must prove there was no discrimination · every employer
  • 18(2)Skip the reporting and the burden shifts to you anyway · every employer
  • 18(3)Your state may set evidence rules kinder to the worker · every employer
  • 18(4)Where the court investigates itself, the shift need not apply · every employer
  • 18(5)It does not apply to criminal proceedings · every employer

Proof of equal work or work of equal value

  • 19(1)A comparison is not limited to one employer · every employer
  • 19(2)A comparator need not work there at the same time · every employer
  • 19(3)With no real comparator, statistics may prove the claim · every employer

Access to evidence

  • 20(1)A court can order you to hand over your pay evidence · every employer
  • 20(2)That order can reach confidential material · every employer
  • 20(3)Your state may give claimants more than this · every employer

Limitation periods

  • 21(1)A claim has at least three years to be brought · every employer
  • 21(2)The clock stops the day the worker complains to you · every employer
  • 21(3)It does not touch rules on when claims expire · every employer

Penalties

  • 23(1)Your state sets fines that bite, and they may be fines · every employer
  • 23(2)The penalties include fines, and must deter · every employer
  • 23(3)Intersectional discrimination counts as an aggravating factor · every employer
  • 23(4)Repeat breaches carry their own penalties · every employer
  • 23(5)Your state must actually apply them · every employer

Equal pay in public contracts and concessions

  • 24(1)Public buyers must police equal pay in their contracts · public buyer
  • 24(2)They may add penalties and termination clauses · public buyer

Victimisation and protection against less favourable treatment

  • 25(1)Never treat a worker worse for raising equal pay · every employer
  • 25(2)Dismissal for raising it must be protected against · every employer

Questions

Does the Pay Transparency Directive apply to my company?
Not directly. A directive binds the member state, so what reaches you is your country's transposing law. 4 of states have one.
When is the first pay gap report due?
The Directive's latest dates are 7 June 2027 at 250 workers or more and 7 June 2031 at 100 to 149. Your national act may ask earlier.
What are the seven figures?
The pay gap, the gap in variable components, both medians, who receives variable components, the quartile bands, and the gap by category of workers.
When does a joint pay assessment become compulsory?
When three things are true at once: a category shows a gap of at least five percent, it is unjustified, and it is not fixed within six months.
Do we have to publish pay ranges in job adverts?
Applicants must be told the initial pay or its range before the interview, and you may not ask about their pay history. Your act may require it in the advert.

Pay transparency duties with their evidence

The Directive's duties as a catalogue, read against your state's law, with the evidence for each, in one workspace.

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