Directive guide

Every deadline in the Pay Transparency Directive

By , founder of Egalis ·

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 of the national law: the pay range before every interview, the 2-month answer to any worker’s pay-information request and the annual reminder of that right. Employers that report also run 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. 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

SizeFirst reportThen
250+ employeesby 7 June 2027annual
150–249 employeesby 7 June 2027every 3 years
100–149 employeesby 7 June 2031every 3 years
Under 100 employeesvoluntary—

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).

Next step

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Updated: 26 September 2026. Figures reflect Directive (EU) 2023/970, unchanged — the Commission has ruled out any postponement, and its FAQ of 6 August 2026 confirms the reporting calendar. The transposition deadline of 7 June 2026 has passed: as of September 2026 only Italy, Slovakia, Lithuania, Malta and Greece have complete implementing laws, and most member states are still drafting. Where your country has no implementing law yet, the Directive is the reference; national rules may be stricter once adopted.

Egalis does not provide legal advice; for specific situations, consult an employment lawyer.