Question and answer

Does the Pay Transparency Directive apply to companies under 100 employees?

By , founder of Egalis ·

In short

Yes — everything except mandatory gap reporting and the joint pay assessment that can follow it. Pay structures built on objective, gender-neutral criteria (Art. 4), pay ranges in recruitment, the ban on pay-history questions, gender-neutral vacancies, 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.

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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.