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EU Pay Transparency Directive: a country-by-country guide for employers

What the EU Pay Transparency Directive requires, the key dates, and how it sits alongside existing gender pay gap rules in Ireland, Germany, France, Belgium, the Netherlands, Poland and the UK.

The EU Pay Transparency Directive (EU) 2023/970 sets one minimum standard for all 27 EU member states. Each country had to bring it into its own law by 7 June 2026, and several have been late or have added their own rules. If you employ people in more than one country, the honest answer to "what do we have to do?" is: the EU baseline, plus whatever each country already had or has added.

This guide is general information, not legal advice. Check the current national law, or ask an employment solicitor, before relying on any date or threshold.

What the directive requires everywhere in the EU

  • Pay before hiring (Article 5) — job applicants must be told the starting pay or pay range, and employers may not ask about their pay history.
  • Clear pay criteria (Article 6) — staff must be able to see the objective, gender-neutral criteria used to set pay and progression. Countries may exempt employers with fewer than 50 staff from the progression part.
  • Right to information (Article 7) — any worker can ask for their own pay level and the average pay, split by sex, for people doing the same work or work of equal value. The employer must answer within two months. Pay-secrecy clauses are no longer allowed.
  • Gender pay gap reporting (Article 9) — phased by headcount (see below).
  • Joint pay assessment (Article 10) — if a report shows a gap of 5% or more in any category of workers that the employer can't justify on objective, gender-neutral grounds and doesn't fix within six months, the employer must carry out a joint pay assessment with worker representatives.
  • Burden of proof and compensation — in a pay discrimination claim the employer has to show there was no discrimination, and workers can claim full back pay.

When EU gap reporting starts

  • 250+ staff — first report by 7 June 2027, then every year.
  • 150–249 staff — first report by 7 June 2027, then every 3 years.
  • 100–149 staff — first report by 7 June 2031, then every 3 years.
  • Under 100 staff — no duty under the directive, though a country may add one.

The first 2027 reports cover the 2026 calendar year, so the pay data you hold right now is the data you will report on.

Country by country

Ireland

Ireland already has gender pay gap reporting under the Gender Pay Gap Information Act 2021. Since 2024 it applies to employers with 50 or more staff: you pick a snapshot date in June and publish the report within six months of that date. The directive's pay-range, pay-information and joint-assessment rules come on top of this.

Germany

The Entgelttransparenzgesetz (Pay Transparency Act, 2017) already gives workers in employers with more than 200 staff a right to pay information, and requires employers with more than 500 staff that must publish management reports to report on equal pay. This law is being reworked to meet the directive, so expect the thresholds and timings to change.

France

Employers with 50 or more staff must calculate and publish the Index de l'égalité professionnelle every year by 1 March. France is replacing the Index with the directive's gap indicators, so the format will change.

Belgium

Under the 2012 Gender Pay Gap Act, employers with 50 or more staff must carry out a pay structure analysis every two years, and pay data by sex appears in the social balance sheet. The directive's rules are being added on top.

Netherlands

There is no national gender pay gap report today. The Dutch government has said its implementing law will start later than the EU deadline, with 1 January 2027 announced as the target. Until then the directive's headline duties are coming, not yet law.

Poland

Poland moved early on one part: since 24 December 2025 employers must give job applicants the pay or pay range and may not ask about pay history. There is no national gap report yet; the directive's reporting rules will apply on the EU timetable.

United Kingdom (not in the EU)

The directive does not apply. Great Britain has its own gender pay gap reporting for employers with 250 or more staff, using a 5 April snapshot (31 March in the public sector) and published within 12 months.

Where MySalaryPal fits

MySalaryPal works from the payroll figures you already produce. For each site it shows which of these duties apply at your current headcount and date, lets staff send Article 7 requests with the two-month clock tracked, and builds gender pay gap figures by category from your imported pay runs. It does not give legal advice or file reports with any authority for you.

Common questions

When did the EU Pay Transparency Directive come into force?

It was adopted in 2023 and member states had until 7 June 2026 to bring it into national law. Some countries are late, so the exact start date in each country depends on its own law.

When is the first EU gender pay gap report due?

By 7 June 2027 for employers with 150 or more staff, covering 2026. Employers with 100–149 staff report first by 7 June 2031.

What is the 5% rule?

If a gap of 5% or more in average pay between women and men in a category of workers can't be justified on objective, gender-neutral grounds and isn't fixed within six months, the employer must do a joint pay assessment with worker representatives.

Does the directive apply to small employers?

Pay ranges in job ads, the pay-history ban and the right to pay information apply regardless of size. Gap reporting only applies from 100 staff, though some countries already require it from 50.

Does it apply in the UK?

No. The UK is not in the EU. Great Britain has its own gender pay gap reporting for employers with 250 or more staff.

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