Pay transparency directive deadlines: what is due in 2026, 2027 and 2031
By the Equaudit team · Updated · 3 min read
Most employers ask the same first question about the EU Pay Transparency Directive: when does it hit us? The answer depends on your headcount and, because the directive has to become national law first, on the country. This page gives the EU-level calendar and explains how to plan around the uncertainty.
The EU-level timeline
| Date | What happens |
|---|---|
| 6 June 2023 | The directive enters into force. |
| 7 June 2026 | Deadline for member states to adopt national laws (transposition). |
| 7 June 2027 | First pay gap reports due from employers with 150 or more workers. Employers with 250 or more then report every year; those with 150 to 249 every three years. |
| 7 June 2031 | First pay gap report due from employers with 100 to 149 workers, then every three years. |
The first reports cover the calendar year that precedes the reporting date, so a report filed in June 2027 normally describes pay in 2026. That detail is the reason many HR teams are already pulling 2026 payroll data into a structure they can analyse.
Some duties do not wait for reporting
Reporting is the only duty with a headcount-based calendar. The other core rules start when the national law applies: pay information for applicants before the interview, the ban on asking about pay history, transparent pay-setting criteria and the worker's right to request pay information. Read more in the employer guide.
Because the transposition date has passed, countries that have already adopted their laws can apply these duties today. In countries that have not, the rules arrive when the law does, often with little notice.
The state of national transposition
Law firm trackers published after the June 2026 deadline described an uneven picture. Only a handful of member states, reported to include Italy, Lithuania, Malta and Slovakia, had completed their laws, while a few others had partial measures and most, including large economies such as France and Germany, still had draft legislation in progress. Some countries had not started a formal process. Commentators also stressed that the European Commission had not postponed the directive.
This moves quickly, so treat any snapshot as a starting point. Ask local counsel or your payroll provider for the current status in each country where you have employees, and watch for national details such as lower reporting thresholds, different report formats or earlier dates.
How to plan when the law is still moving
- Plan on the EU dates. If you have 150 or more workers, assume a first report in June 2027 covering 2026 pay. If your national law lands late, you lose nothing by being ready.
- Run a trial now. A trial analysis on 2025 or 2026 data shows your headline gap and any category at or above 5% while there is still time to act. See the 5% rule.
- Fix job ads first. Pay ranges, gender-neutral titles and no questions about pay history are easy wins and apply as soon as your national law does. See salary ranges in job ads.
- Build your categories early. Grouping jobs of equal value is the slowest task and the one most employers underestimate. See defining job categories.
- Count headcount per country. Thresholds apply to the employer's workforce under the national law, so multinational groups may sit in different calendars in different countries.
Frequently asked questions
When is the first pay gap report due?
Under the directive, employers with 150 or more workers must file a first report by 7 June 2027, normally covering the previous calendar year. Employers with 100 to 149 workers follow on 7 June 2031. National laws can set earlier dates or lower thresholds.
How often do I have to report after the first report?
Employers with 250 or more workers report every year. Employers with 100 to 249 workers report every three years.
My country has not adopted its law yet. Do I still need to prepare?
Yes. The EU dates have not changed and national laws are expected to follow them. Preparation such as cleaning payroll data, defining job categories and fixing job ads takes months, and is far cheaper than a rushed filing.