Question and answer
Does the Pay Transparency Directive apply to companies under 100 employees?
In short
Yes — everything except mandatory gap reporting. Pay ranges in recruitment, the ban on pay-history questions, gender-neutral vacancies, objective and accessible pay criteria, and workers' right to pay information all apply to employers of every size. Only the Art. 9 reporting duty starts at 100 employees (member states may extend it lower).
In detail
Member states may exempt employers with fewer than 50 workers from publishing pay-progression criteria (Art. 6) — the rest of Art. 6 still applies.
Equal pay for equal work and work of equal value has applied to every employer since long before this Directive — the Directive adds the transparency machinery that makes it enforceable.
Small employers are most exposed in recruitment: the pay-range and no-history rules are visible to every candidate — and to inspectors.
More questions with direct answers: the FAQ.