The EU Pay Transparency Directive: what employers report

Who reports, and when

The reports cover the previous calendar year (Article 9). Employers with fewer than 100 workers may report voluntarily, and a country can require them to.

Member States had to bring the directive into national law by 7 June 2026 (Article 34). A country may instead compile indicators (a) to (f) itself from tax or social security data (Article 9(8)).

The seven indicators of Article 9(1)

Indicators (a) to (g) go to the authority each country names to compile them, and the employer may publish (a) to (f). Indicator (g) goes to all workers and their representatives, and to the labour inspectorate and equality body on request. Management confirms the accuracy of the figures after consulting workers’ representatives, who have access to the methods used (Article 9(6), (7) and (9)).

The terms that decide the numbers

• Pay is the ordinary basic or minimum wage or salary and any other consideration, in cash or in kind, received from the employer: the complementary or variable components (Article 3(1)(a)). Recital 21 lists bonuses, overtime compensation, travel facilities, housing and food allowances, training compensation, dismissal payments, statutory sick pay, statutory required compensation and occupational pensions as possible examples.
• Pay level is gross annual pay and the corresponding gross hourly pay (Article 3(1)(b)); recital 22 says pay levels should be expressed both ways, from the actual pay however it is set.
• The gender pay gap is the difference between the average pay levels of female and male workers, as a percentage of the male average; the median gap does the same with medians (Article 3(1)(c) to (e)). As in the UK and Ireland, that is (A − B) ÷ A × 100 with A the figure for men.
• A quartile pay band is one of four equal groups of workers, from lowest to highest pay (Article 3(1)(f)).
• A category of workers groups workers doing the same work or work of equal value, in a non-arbitrary way, on objective, gender-neutral criteria (Article 3(1)(h)); Article 4(4) names skills, effort, responsibility and working conditions.

The European Commission’s FAQ of 6 August 2026, which it describes as the preliminary views of its services, says pay reporting starts from all elements of pay of the workers employed in the reporting period, that benefits in kind may need a money value, that employer contributions to occupational pension schemes always count, and that benefits given to every employee without conditions, such as lunch vouchers, need not be included.

The joint pay assessment at 5%

Under Article 10, an employer that reports must carry out a joint pay assessment with workers’ representatives when all three conditions hold:

1. the reporting shows a difference in average pay level between female and male workers of at least 5% in any category of workers;
2. the employer has not justified that difference on objective, gender-neutral criteria; and
3. the employer has not remedied it within six months of submitting the report.

The assessment covers the share of women and men in each category, their average pay levels and variable pay, the reasons for any differences, pay improvements after maternity, paternity, parental or carers’ leave, the measures to close unjustified differences, and how well earlier measures worked (Article 10(2)). The directive does not say whether the 5% is measured on annual or hourly pay, so the calculator shows both and flags categories where the hourly gap is 5% or more in either direction.

Pay information rights for workers and applicants

• Applicants are told the initial pay or its range, for example in the job advert or before the interview, and employers may not ask about their pay history (Article 5).
• Workers can see the criteria used for pay, pay levels and pay progression; countries may exempt employers with fewer than 50 workers from the progression part (Article 6).
• Workers can ask in writing for their own pay level and the average pay levels, by sex, of the category of workers doing the same work or work of equal value, and must get an answer within two months. Employers remind all workers of this right every year, and contract terms that stop workers from disclosing their pay are prohibited (Article 7).

These rights reach workers through national law, which was due by 7 June 2026; when and how they apply in a country depends on that law.

Official information by country

Each country’s own law sets the reporting format, the authority and the penalties. These official pages were checked on 8 October 2026; they describe each country’s own steps and are not a full list.

The European Commission’s equal pay page carries its FAQ on the directive and the EU guidelines on gender-neutral job evaluation.

How the calculator handles the indicators

Choose “EU directive”, then drop a file with basic pay and complementary or variable pay for the year, the hours paid and each worker’s category. It works out (a) and (c) on both gross hourly and gross annual pay, (b), (d) and (e) for the workers who received variable pay, (f) by hourly pay, and (g) for every category, split into basic and variable pay, with the 5% flag. Where the directive leaves a choice open, the calculator says which choice it made, so you can check it against your national law.