Directive guide
Pay gap reporting: the 7 metrics, step by step
By Mihai Postolache, founder of Egalis ·
In short
1. Who reports, and when
| Size | First report | Frequency |
|---|---|---|
| 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 |
The report covers the preceding calendar year. Below 100 employees reporting is voluntary unless the member state extended it.
2. The 7 metrics (Art. 9(1) a–g)
- the mean gender pay gap
- the mean gap in complementary or variable components (bonuses, commissions, benefits)
- the median gender pay gap
- the median gap in complementary or variable components
- the proportion of female and male workers receiving variable components
- the proportion of female and male workers in each quartile pay band
- the pay gap for each category of workers doing the same work or work of equal value, split into ordinary basic salary and variable components
Metric (g) is the one with teeth
The per-category gap is where the 5% threshold applies, where justification on objective criteria is judged, and what workers’ representatives will look at first. The six aggregate metrics describe the company; metric (g) decides whether you have a legal problem.
3. The mechanics that decide whether your numbers are right
- Complete pay, not base salary — variable components and benefits in kind enter the calculation (Art. 3).
- Hourly comparability — part-time work must not masquerade as a pay difference: normalise to gross hourly pay / full-time equivalent.
- Stable categories — the same job evaluation across years, versioned; changing categories between reports without documentation reads as gap management.
- A reproducible method — representatives are entitled to ask how the figures were produced; “the consultant’s spreadsheet” is not an answer. Egalis freezes each report with its parameters and audit trail.
4. After submission
The monitoring body publishes employer-level data, so your gap becomes comparable — candidates, journalists and competitors will read it. Unjustified differences must be remedied in cooperation with workers’ representatives, and a ≥ 5% per-category gap left unjustified and unremedied for 6 months triggers the joint pay assessment. The companies that will look good in 2027 are the ones watching their categories monthly in 2026 — start with the calculator.
Frequently asked questions
Which pay counts in the calculation?
Complete remuneration: ordinary basic salary plus complementary or variable components — bonuses, commissions, overtime, benefits in kind. Reporting basic salary alone understates the gap and does not comply with Art. 3.
Who confirms the figures?
The employer's management confirms the accuracy of the report, after consulting workers' representatives — who have access to the methodology behind the figures (Art. 9(5)).
Where does the report go, and who sees it?
Metrics (a)–(f) go to the national monitoring body (Art. 29), which publishes the employer-level data. Metric (g) — the per-category gap — is shared with workers and their representatives, and with the labour inspectorate and the equality body on request. Public comparability between employers is part of the design. The channel and the format of the report are set by national law.
Can we outsource the report to our accountant?
The arithmetic, perhaps — but the report stands on categories of work of equal value, which require a documented job evaluation, and on choices (FTE normalisation, benefit valuation) that must be consistent and explainable to representatives. That is a system, not a spreadsheet.
Next step
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