Free checklist

EU Pay Transparency Directive
readiness checklist.

21 things to have in place before your first report is due. Tick them off here, print it, or take it into your next leadership meeting. Written for HR teams with 100 to 1,000 employees in one or several EU countries.

Go to the checklist ↓ What the Directive requires

0 of 21 done — your ticks are saved in this browser.

1 · Scope and data
Know which entities are in scope, when, and whether the data exists to report at all.
  • 01Confirm which legal entities employ 100 or more workers in each member state, and which first reporting date applies to each (7 June 2027 for 150+, 7 June 2031 for 100–149).
  • 02Identify the transposing law in every country where you employ people, and any stricter national rule: earlier dates, lower thresholds, extra report content.
  • 03Make sure every worker record holds sex, category of work, basic pay, variable components, hours or FTE and start date — in one system, not across spreadsheets.
  • 04Define the categories of workers doing the same work or work of equal value, using objective, gender-neutral criteria: skills, effort, responsibility and working conditions.
  • 05Name the owners: an HR lead, legal counsel, finance for the pay data, and the workers' representatives who will see the report.
2 · Pay structures and hiring
The obligations that apply to every employer, whatever its size.
  • 06Document the pay bands for each category and the criteria used to set pay and pay progression — workers have a right to access those criteria.
  • 07Check that job titles and vacancy notices are gender-neutral.
  • 08Add the starting pay or pay range to vacancy notices, and remove any question about pay history from application forms and interview guides.
  • 09Remove pay-secrecy clauses from contracts, handbooks and policies.
3 · Gap analysis
Run the numbers before anyone else does.
  • 10Calculate the mean and median gender pay gap overall, per category of workers, and separately for variable components.
  • 11Flag every category with a gap of 5% or more and look for an objective, gender-neutral justification.
  • 12Where a gap cannot be justified, plan and budget remediation within six months — that is what avoids a joint pay assessment.
  • 13Keep the working papers: the data snapshot, the method, and the decisions taken. If a claim comes, the burden of proof is on you.
4 · Employee rights
Article 7 requests can arrive from day one of the national law.
  • 14Set up a channel and a response template for pay-information requests, and track the two-month deadline for each one.
  • 15Prepare the annual notice that reminds workers of their right to request pay information.
  • 16Brief managers on what they may and may not say about pay, and where to send questions.
  • 17Make the criteria for pay and pay progression easily accessible to workers.
5 · Reporting
The report itself is the last step, not the first.
  • 18Map the Directive's reporting fields to your data, and find out which national body receives the report and in what format.
  • 19Agree how the report is shared with workers' representatives, and who in management confirms its accuracy.
  • 20Diarise the deadlines — 7 June 2027 for employers with 150 or more workers, 7 June 2031 for 100–149 — or the national dates if they come first.
  • 21Rehearse the full cycle once with last year's data before the first real report.

This checklist summarises Directive (EU) 2023/970 as adopted. Member states transpose it into national law and may add or tighten obligations; it is general information, not legal advice. Check the rules of each country where you employ people.

From checklist to report

Points 10 to 13
take an afternoon in SincHR.

Import your people data, define categories, and read your mean and median gap per category — with the working papers kept for you.

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