When does the EU Pay Transparency Directive apply?

Member States had to transpose it into national law by 7 June 2026, and by October 2026 six had done so. Pre-hiring transparency and pay information rights apply once national law takes effect. Pay gap reporting starts in June 2027 for employers with 150 or more employees and in June 2031 for those with 100 to 149.

Which companies must report their gender pay gap?

Employers with 250 or more employees report every year from 2027, those with 150 to 249 every three years from 2027, and those with 100 to 149 every three years from 2031. Smaller employers may report voluntarily or if national law requires it.

What happens if the gender pay gap is 5% or more?

If a gap of 5% or more in any category of workers is not justified by objective, gender-neutral criteria and is not corrected within six months, the employer must carry out a joint pay assessment with employee representatives.

Can employers still ask candidates about their salary history?

No. Employers must not ask about current or past pay, and must share the initial pay or pay range before pay discussions begin, either in the job advert or before the interview.

What are the penalties for non-compliance?

Each Member State sets effective, proportionate and dissuasive penalties, such as fines, exclusion from public contracts and withdrawal of subsidies. Workers can also claim full back pay with no cap, and the burden of proof shifts to the employer.

Is the Pay Transparency Directive Guide free?

Yes. Fill in the form on this page and the PDF downloads immediately. The guide was updated in October 2026.

Which countries have already transposed the Directive?

By October 2026, six Member States had transposed it: Slovakia, Italy, Lithuania, Malta, Greece and Estonia, the last one only partially. The other 21 are at different stages, from bills before Parliament to no published draft.

EU Pay Transparency Directive Guide 2026

A free PDF for employers and HR teams: what Directive (EU) 2023/970 requires, when each obligation applies and where each Member State stands.

What's inside the guide:

Keypoints: what the Directive is, who is covered and why it matters
How it works: before hiring, during employment and in reporting
Key deadlines by company size
Country-by-country status for all 27 Member States
How to run your pay gap analysis with TalentUp

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What is the EU Pay Transparency Directive?

The EU Pay Transparency Directive (Directive (EU) 2023/970) is a binding EU law that aims to close the gender pay gap by enforcing equal pay for equal work or work of equal value between women and men. It is grounded in Article 157 of the Treaty on the Functioning of the European Union.

It applies to all public and private employers in the EU and protects full-time, part-time and temporary employees, platform workers and, for pre-hiring transparency, job applicants.

This guide explains what the Directive requires from employers. To see how each Member State is transposing it, check our country-by-country Pay Transparency tracker.

Topics covered in the guide: what the Directive is, who is involved, key deadlines, pre-hiring actions, pay gap reporting, joint pay assessments and employer and employee rights

Key deadlines of the EU Pay Transparency Directive

Date	What happens
June 2023	The Directive is adopted.
7 June 2026	Deadline for Member States to transpose the Directive into national law.
June 2027	First gender pay gap reports: annual for employers with 250 or more employees, every three years for 150 to 249 employees.
June 2031	Reporting starts for employers with 100 to 149 employees, every three years.
Ongoing	Pre-hiring transparency and pay information rights apply as soon as national law takes effect.

Employers with fewer than 100 workers may report voluntarily or if national legislation requires it.

Key employer obligations

Pre-hiring pay transparency

State the initial pay or pay range in the job advert or before the interview, use gender-neutral job titles and never ask candidates about their current or past salary.

Objective pay structures

Explain how pay and career progression are set, using objective, gender-neutral criteria such as skills, experience and performance. Member States may exempt employers with fewer than 50 workers.

Right to pay information

Workers can request their own pay level and the average pay, broken down by gender, for colleagues doing the same work or work of equal value. Employers must answer within two months and remind staff of this right every year.

Gender pay gap reporting

Reports must include the mean and median gender pay gap, the gap in variable pay, the share of men and women receiving variable pay, the gender distribution in pay quartiles and the gaps by category of workers.

Joint pay assessments

A gender pay gap of 5% or more in any category of workers that is not objectively justified and not corrected within six months triggers a joint pay assessment with employee representatives.

Worker rights and penalties

Workers can claim full back pay with no cap, the burden of proof shifts to the employer, and claims can be filed for at least three years. Penalties include fines and exclusion from public contracts.

Pay gap reporting deadlines by company size and the metrics each report must include

Implementation checklist for employers

Whatever stage your country is at, these are the first steps to prepare your organisation:

1 Review your job evaluation and classification system for gender neutrality.
2 Draft or update your pay transparency and pay equity policies.
3 Add pay ranges to job adverts and remove salary history questions.
4 Set up a process to answer pay information requests within two months.
5 Collect and analyse your pay data to find and justify gender pay gaps before reporting.
6 Train HR and managers, and involve employee representatives and legal advisors early.

Countries where the Directive is already in force

The guide covers all 27 Member States. By October 2026, six had transposed the Directive, and each one adds its own national twist:

Slovakia

First Member State to transpose, with an Equal Pay Act in force since 7 June 2026.

Italy

Collective bargaining agreements are central, and pay information requests are limited to one per year.

Lithuania

Rules reach employers of every size, and pay gap indicators are calculated centrally by Sodra.

Malta

Transposed in two steps, with documented pay criteria required from 25 employees.

Greece

Fifth to transpose, through Law 5316/2026. Recruitment pay transparency applies to every employer, whatever its size, from 1 November 2026.

Estonia

A partial transposition in force since 13 July 2026: pay ranges before interviews and no pay-secrecy clauses, with reporting deferred.

The other 21 Member States are at different stages, from bills before Parliament to no published draft. The guide includes a profile for each of them.

Track the transposition status in all 27 Member States →