EU Pay Transparency Directive

EU compliance,
sorted.

The EU Pay Transparency Directive is being transposed into national law across member states. SincHR supports pay-transparency preparation and documentation — pay gap calculation, employee pay information requests, and structured exports. Software does not guarantee compliance.

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What is it?

The EU Pay Transparency Directive — explained simply.

Directive 2023/970 requires EU employers to be open about pay, work to close pay gaps, and give employees the right to request their own pay level and the average pay level, broken down by sex, for colleagues doing equal work or work of equal value — not unrestricted access to any individual colleague's salary.

Art. 5
Pay transparency before employment
Once your country's transposing law is in force, employers must provide pay or pay range information in job postings or before interviews, and cannot ask candidates about their pay history. Exact requirements and timing vary by member state.
✓ SincHR: Pay band publishing for job posts
Art. 7
Right to information for workers
Employees can request information on their individual pay level and average pay levels, broken down by gender, for workers doing the same work.
✓ SincHR: Employee self-service pay portal
Art. 9
Pay reporting obligations
EU baseline: employers with 250+ employees report annually from 7 June 2027 (covering 2026 data). Employers with 150–249 employees report every 3 years from the same date. Employers with 100–149 employees report every 3 years from 7 June 2031. National law can set earlier or broader duties.
✓ SincHR: pay gap calculation and report generation
Art. 10
Joint pay assessment
When a reporting employer's category-level pay gap is at least 5%, is not justified by objective, gender-neutral criteria, and remains unaddressed 6 months after reporting, the employer must carry out a joint pay assessment with worker representatives.
✓ SincHR: gap analysis and assessment workflow (flags, does not decide)
Key Deadlines

When does it apply to you?

The Directive was adopted in May 2023. Member states were required to transpose it into national law by 7 June 2026 — actual implementation status varies by country.

✓
May 2023
Directive adopted
EU Pay Transparency Directive (2023/970) officially published in the EU Official Journal.
Done
✓
7 June 2026
National transposition deadline
This was the deadline for EU member states to transpose the Directive into national law. Implementation timing and detail vary by country — check your national law for exact rules.
Deadline passed
🏗
7 June 2027
First Article 9 reporting deadline
Employers with 250+ employees submit their first annual gender pay gap report, covering 2026 data. Employers with 150–249 employees submit their first report too, on the same date. Pay information rights (Articles 5 and 7) apply once your country's transposing law is in force.
250+ employees · annual
📋
2027
150–249 employees: first report
Employers with 150–249 employees submit their first report on 7 June 2027, then every three years.
150–249 employees · every 3 years
📋
2031
100–149 employees: first report
Employers with 100–149 employees submit their first report on 7 June 2031, then every three years. No EU-wide Article 9 duty applies below 100 employees, though national law may differ.
100–149 employees · every 3 years
How SincHR helps

Everything covered, automatically.

Pay Gap Reporting

Generate your EU report in minutes.

SincHR calculates your organisation's pay gap across the required dimensions and prepares a structured report for your review. You submit to the relevant national authority; exact submission formats vary by member state.

  • ✓Gender pay gap by department, role, and seniority
  • ✓Mean and median pay gap calculations
  • ✓Bonus and variable pay gap tracking
  • ✓Export in formats required by member states
Sample data · illustration only — Pay Gap Report4/5 no gap flagged
DepartmentHeadcountPay GapStatus
Engineering681.8%✓ Below threshold
Sales422.4%✓ Below threshold
Operations555.1%⚠ Flagged for review
Marketing311.2%✓ Below threshold
Legal & Finance510.9%✓ Below threshold
4 of 5 departments below the review threshold · Export PDF →
Employee Pay Portal

Give employees the information they're entitled to.

Article 7 of the Directive gives employees the right to request their pay level and average pay levels for comparable roles. SincHR provides a self-service portal for these requests and tracks the response.

  • ✓Self-service employee portal for pay information requests
  • ✓Anonymised comparison data across comparable roles
  • ✓Request tracking and response audit log
  • ✓Deadline reminders (employers have 2 months to respond)
Sample data · illustration only — Pay Information RequestFulfilled in 2 days
Request from: J. Hoffman, Engineering
Requested: Avg pay for comparable roles
Response (anonymised)
Your salary€68,000
Median for role€71,500
Based on 12 comparable employees
✓ Request fulfilled · Response sent 18 Apr 2025
FAQ

Compliance questions, answered.

Does the Directive apply to companies outside the EU?+
The Directive binds EU member states, which apply it through their own national laws to employers with employees in that country — regardless of where the company is headquartered. Your specific obligations depend on where your employees are located and how each country has transposed the Directive.
What happens if we don't comply?+
Penalties are set by individual member states under their transposing legislation and can include fines. Employees may also be able to bring claims in national courts. Check your national law for the specific penalty regime.
What counts as a "pay gap" under the Directive?+
The Directive focuses on the gap between average pay for male and female workers doing "work of equal value" — meaning the same or comparable roles, taking into account factors like seniority and experience. It includes base pay, bonuses, and variable components.
Can we use SincHR for the actual regulatory submission?+
SincHR generates reports in the data formats required by the relevant member state authorities. You then submit directly to the relevant national authority. We're working on direct integrations with national portals where APIs are available.
We have fewer than 100 employees — do we need to do anything?+
At the EU baseline, the formal Article 9 reporting obligation applies only to employers with 100+ employees. The pay information rights in Articles 5 and 7 apply more broadly, once your country's transposing law is in force — check your national law for exact scope. Some member states already impose broader duties on smaller employers.
When do the reporting obligations start?+
Member states must transpose the Directive by 7 June 2026. Employers with 250 or more workers report for the first time by 7 June 2027 and then every year; employers with 150–249 workers report by 7 June 2027 and then every three years; employers with 100–149 workers report for the first time by 7 June 2031, then every three years. National laws may set earlier dates or lower thresholds.
What exactly has to be reported?+
The gender pay gap in mean and median terms, the gap in complementary or variable components, the proportion of women and men receiving such components, and the pay gap broken down by categories of workers and by basic pay versus variable components. Part of the report is shared with workers and their representatives, and the employer's management must confirm its accuracy.
What is a joint pay assessment and when is it triggered?+
If a report shows a gender pay gap of at least 5% in any category of workers that cannot be justified by objective, gender-neutral criteria and is not remedied within six months, the employer must carry out a joint pay assessment with workers' representatives: examine the causes, and agree and implement corrective measures.
What can employees ask for under Article 7?+
Any worker may ask, in writing, for their own pay level and the average pay levels, broken down by sex, for the category of workers doing the same work or work of equal value. The employer must answer within a reasonable time and at the latest within two months, and must remind workers of this right every year.
Does the Directive change how we recruit?+
Yes. Applicants have the right to know the starting pay or pay range for a position before the interview — for example in the vacancy notice — and employers may no longer ask candidates about their current or previous pay. Vacancy notices and job titles must be gender-neutral.
Can we still ask employees to keep their pay confidential?+
No. Workers cannot be prevented from disclosing their pay for the purpose of enforcing equal pay, and contractual clauses that try to do so are unenforceable. Employers may ask that information obtained through an Article 7 request is used only for that purpose.
Who has to prove what in a pay-discrimination claim?+
Once a worker establishes facts from which discrimination may be presumed, it is for the employer to prove there was none. Where the employer has not met its transparency obligations, the burden of proof shifts to the employer in any case. Keeping evidence of how pay decisions were made is therefore part of compliance.
Do part-time, fixed-term and agency workers count towards the thresholds?+
The Directive applies to all workers with an employment contract or employment relationship as defined by national law, including part-time and fixed-term workers. Headcount is generally assessed per employer (legal entity), but how workers are counted — and whether agency workers count for the user company — is set by the transposing law, so check the national rules.
What counts as "pay"?+
Pay is broad: the ordinary basic wage or salary plus any other consideration in cash or in kind received directly or indirectly — bonuses, overtime, allowances, benefits in kind, occupational pension contributions and similar. That is why pay-gap analysis has to cover variable components, not only base salary.
EU pay transparency reporting

Prepare for pay transparency,
on your terms.

See how SincHR supports pay-transparency preparation and documentation with your own data. Applicable requirements depend on national law; software does not guarantee compliance.

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