When does my company have to report its gender pay gap?

The thresholds and dates come from Art. 9 of Directive (EU) 2023/970 — they are the floor. Member states may lower thresholds or bring dates forward in their implementing laws, so check your national law too: as of September 2026 only Italy, Slovakia, Lithuania, Malta and Greece have complete implementing laws, and most member states are still drafting.

Watch your growth: the band is judged on your real headcount. Crossing 150 puts you in the 2027 wave — and because reporting covers the preceding year, the data starts counting a year earlier.

Job evaluation on "work of equal value" takes time (committees, workers' representatives) — employers who start a year before their first report do it without a crisis.