The EU Pay Transparency Directive introduces mandatory gender pay gap reporting for employers across all 27 member states. For HR teams operating in Europe, this is the most significant new compliance obligation since GDPR. The first reporting cycle covers 2026 data, with publication due June 2027 for large employers.
Who must report and when
- Employers with 250 or more employees: annually from June 2027
- Employers with 150 to 249 employees: every three years from June 2027
- Employers with 100 to 149 employees: every three years from June 2031
The eight required data points
The Directive specifies eight data points broken down by category of workers and gender: gender pay gap in ordinary basic pay, gender pay gap in supplementary pay, median gaps for both, the proportion of workers receiving supplementary pay by gender, pay quartile distribution, and paternity/adoption leave uptake. This is significantly more detailed than existing UK or Irish gender pay gap reporting.
The 5% investigation trigger
If your report shows a gender pay gap of 5% or more in any category that cannot be objectively justified within six months, the Directive requires a joint pay assessment conducted with employee representatives. This is the provision most large employers are focused on preparing for.
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Start free trialPreparing now for 2027
- Audit whether your HRIS can produce all eight required data points
- Define your categories of workers using objective criteria
- Baseline your current pay gap position
- Identify and remediate unexplained gaps before first public reporting
- Brief employee representatives on the co-determination process
See our full EU Pay Directive guide for the complete requirements.