Directive guide
Every deadline in the Pay Transparency Directive
By Mihai Postolache, founder of Egalis ·
In short
1. The fixed milestones
- 6 June 2023 — Directive (EU) 2023/970 entered into force.
- 7 June 2026 — transposition deadline for every member state. Most missed it, so check whether your country’s law is already in force (where each member state stands).
- 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)).
For employers that report (100+ employees):
- 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 (including 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 applies the Directive itself for employers in any member state. For Slovakia it also applies the national act (Act No. 76/2026 Coll.): legal references, public holidays and the ministry's job-evaluation profile. The Romanian edition at egalis.ro follows the draft law L445/2026. Guides in Bulgarian, Czech, Greek, Croatian, Hungarian, Lithuanian, Polish and Slovak cover the national state of play. For every other member state, the Directive's floor applies — check your national law.
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. Check whether your national implementing law has been adopted: as of September 2026 only Italy, Slovakia, Lithuania, Malta and Greece have complete laws.
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).
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