What the directive says
Article 9 of Directive (EU) 2023/970 requires employers to report seven measures about their organisation:
- the gender pay gap,
- the gender pay gap in complementary or variable components,
- the median gender pay gap,
- the median gender pay gap in complementary or variable components,
- the proportion of women and men receiving complementary or variable components,
- the proportion of women and men in each quartile pay band, and
- the gender pay gap by category of workers, broken down by basic pay and by complementary or variable components.
Read the full article in the official text on EUR-Lex. Each country decides where the report goes and whether a public authority calculates part of it from data it already holds.
What it means in practice
Who reports and how often
Employers with 250 or more workers report every year. Employers with 150 to 249 workers and with 100 to 149 workers report every three years, the smallest group starting later. Below 100 workers reporting is voluntary unless national law requires it. Each report covers the previous calendar year.
Where the report goes
The measures go to the national authority that compiles and publishes them. The employer may also publish the first six measures itself. Some countries calculate them centrally from tax or social security data, so the employer mainly supplies the inputs.
Who sees the category gaps
The seventh measure, the gap by category of workers, goes to all employees and their representatives, and to the labour inspectorate and equality body on request.
Management signs off
Management confirms the accuracy of the figures after consulting workers’ representatives, who have access to the methodology.
Explain or fix the gaps
Workers, their representatives, labour inspectorates and equality bodies can ask for explanations of any figure. Gaps that are not justified by objective, gender-neutral criteria must be remedied.
When a joint pay assessment is required
If the report shows a difference of at least 5% in average pay between women and men in any category of workers, the employer has not justified it with objective, gender-neutral criteria, and has not remedied it within six months, the employer must carry out a joint pay assessment with workers’ representatives (Article 10). National rules decide the details.
Country by country
Thresholds, first reporting years and the reporting channel differ by country. The table comes from our tracker and changes when a country’s law moves.
| Country | Reporting threshold | First report, 250 or more employees | First report, 100 to 149 employees | Reporting model |
|---|---|---|---|---|
| Austria | 100 | Existing biennial GlBG cycle; Upper Austria and Styria regional Directive-specific 250+ reports: first due 7 June 2027 | 7 June 2031 (Upper Austria and Styria regional public-sector employers with 100-149 only) | Pre-existing national reporting |
| Belgium | 100 | By 7 Jun 2027 | By 7 Jun 2031 | Employer-calculated / employer-filed |
| Bulgaria | 100 | By 7 Jun 2027 (proposed) | By 7 Jun 2031 (proposed) | Proposed employer-calculated |
| Croatia | No national rule identified | No national rule identified | No national rule identified | – |
| Cyprus | 100 | By 7 Jun 2027 (proposed) | By 7 Jun 2031 (proposed) | Proposed employer-calculated |
| Czechia | 100 | 30 Apr 2028 (employer work-group filing, proposed) | 30 Apr 2031 (employer work-group filing, proposed) | Proposed hybrid / centralised |
| Denmark | 100 | By 1 Sep 2028 (proposed) | By 1 Sep 2031 (proposed) | Proposed hybrid / centralised |
| Estonia | No national reporting threshold identified | No national reporting deadline identified | No national reporting deadline identified | – |
| Finland | 100 | Employer filing by 2 May 2028 (2027 data); Statistics Finland transmission by 7 Jun 2028 | Employer filing by 2 May 2031 (2030 data); Statistics Finland transmission by 7 Jun 2031 | Proposed hybrid / centralised |
| France | 50 | 2028 (proposed new private-sector Index; current Index retained for the 2027 declaration) | 2028 for the core new private indicators; category-gap indicator may start later by decree, no later than 3 years after promulgation (proposed) | Proposed hybrid / centralised |
| Germany | More than 500 under existing EntgTranspG | – | – | Pre-existing national reporting |
| Greece | 100 | By 7 Jun 2027 | By 7 Jun 2031 | Employer-calculated / employer-filed |
| Hungary | – | – | – | – |
| Ireland | 50 | Existing annual report: within 5 months of June snapshot; Directive dates pending | Existing annual report: within 5 months of June snapshot; Directive dates pending | Pre-existing national reporting |
| Italy | 100 | By 7 Jun 2027 | By 7 Jun 2031 | Employer-calculated / employer-filed |
| Latvia | 100 | By 7 Jun 2027 (proposed) | By 7 Jun 2031 (proposed) | Proposed employer-calculated |
| Lithuania | 100 | 2028 (for 2027 data) | 2031 (for 2030 data) | Hybrid / centralised |
| Luxembourg | – | – | – | – |
| Malta | 100 | By 7 Jun 2027 | By 7 Jun 2031 | Employer-calculated / employer-filed |
| Netherlands | 100 | By 7 Jun 2028 (2027 data) | By 7 Jun 2031 (2030 data) | Proposed employer-calculated |
| Poland | 100 | 7 Jun 2027 (proposed; commencement-dependent first period) | 7 Jun 2031 (proposed) | Proposed employer-calculated |
| Portugal | 50 | 7 Jun 2027 (proposed) | 7 Jun 2031 (50-149, proposed) | Proposed hybrid / centralised |
| Romania | 100 | By 7 Jun 2027 (proposed) | By 7 Jun 2031 (proposed) | Proposed employer-calculated |
| Slovakia | 100 | By 7 Jun 2027 | By 7 Jun 2031 | Employer-calculated / employer-filed |
| Slovenia | – | – | – | – |
| Spain | 50 | By 7 Jun 2027 (proposed) | 7 Jun 2031 for employers with 50-149 workers (proposed) | Proposed employer-calculated |
| Sweden | No Directive-specific reporting threshold identified; annual pay mapping applies under existing law | No active Directive-specific first-report deadline identified | No active Directive-specific first-report deadline identified | Pre-existing national reporting |
How to prepare
- Group roles into categories of equal value. The seventh measure and the 5% test both work per category.
- Collect pay data for the whole calendar year, including variable pay, benefits in kind and hours, so hourly pay can be calculated.
- Run the measures internally first and see which categories show a gap of 5% or more.
- Document the reasons for each gap you can justify with objective, gender-neutral criteria. Statistically explained is not the same as justified.
- Plan corrections for gaps you cannot justify, early enough to act within six months of reporting.
- Agree the process with workers’ representatives, who review the methodology before management signs off.
Questions employers ask
Evenpay calculates the seven measures from your pay data, shows which categories pass the 5% line and keeps the justifications with the figures. See how pay transparency reports work.