Directive guide

Every deadline in the Pay Transparency Directive

In short

Two kinds of deadlines matter: the reporting waves — 250+ and 150–249 employees by 7 June 2027, 100–149 by 7 June 2031 — and the permanent clocks that apply to every employer from day one: the pay range before every interview, the 2-month answer to any worker’s pay-information request, the annual reminder of that right, and the 6-month window before an unjustified ≥ 5% gap becomes a joint pay assessment.

1. The fixed milestones

6 June 2023 — Directive (EU) 2023/970 entered into force.
7 June 2026 — transposition deadline for every member state. From this date, the national implementing laws carry the obligations.
7 June 2027 — first reports from employers with 150+ employees, covering the preceding calendar year.
7 June 2031 — first reports from employers with 100–149 employees.

2. The reporting calendar, by company size

Size	First report	Then
250+ employees	by 7 June 2027	annual
150–249 employees	by 7 June 2027	every 3 years
100–149 employees	by 7 June 2031	every 3 years
Under 100 employees	voluntary	—

The report describes LAST year

Reporting covers the preceding calendar year: the 2027 report describes 2026. Whatever your gap is in the reference year is what gets reported — the real deadline for fixing it is a year before the submission date.

3. The permanent clocks (every employer, every size)

Before every interview — the applicant has received the initial pay or its range, in the vacancy notice or in writing (Art. 5).
2 months — the maximum to answer a worker’s written request for their pay level and the averages by sex for their category (Art. 7).
Annually — employers remind all workers of their right to pay information (Art. 7(3)).
6 months from the reporting date — the window to justify or remedy a mean gap of ≥ 5% in any category before the joint pay assessment obligation lands (Art. 10).

4. What your member state can change

National laws may lower the reporting thresholds (some states extend reporting below 100 employees), bring dates forward, set the reporting channel and forms, and define the penalties. They may also count working days differently for national procedural deadlines. The dates on this page are the Directive’s floor — Egalis country editions carry the national calendars (Romania is live at egalis.ro).

Frequently asked questions

Which year does the first report cover?

The preceding calendar year. A report submitted by 7 June 2027 describes pay in 2026 — which is why the preparation deadline is effectively a year earlier than the reporting date.

Can national deadlines differ from these?

Yes, in one direction: member states may be stricter — lower thresholds, earlier dates, extra obligations. They cannot be more lenient than the Directive. Always check your national implementing law.

What happens if we miss the reporting deadline?

Penalties are national (Art. 23) — fines in most member states. Beyond the fine, missing transparency obligations also flips the burden of proof against you in any equal-pay dispute (Art. 18).