The Ultimate Guide to the EU Pay Transparency Directive.
Everything that changes by 7 June 2026.

Directive (EU) 2023/970 is an EU-wide law that strengthens the principle of equal pay for equal work or work of equal value through pay-transparency and enforcement mechanisms. It was adopted on 10 May 2023 and must be transposed into national law by 7 June 2026.

Member states must transpose the Directive into national law by 7 June 2026. Some obligations — notably gender pay-gap reporting — phase in on staggered dates depending on employer size, running through 2027 for employers with 250+ workers and up to 2031 for those with 100+ workers.

All employers in the EU, public and private, of any size are covered by the equal-pay and pre-employment transparency rules. Reporting obligations apply based on size thresholds — 250+ employees first, then 150+, then 100+.

Yes. Employers must inform candidates about the initial pay level or pay range for the advertised position either in the job vacancy notice or, at the latest, before the first interview. The exact placement (in the ad vs. before interview) is a national-law choice, but disclosure is mandatory.

No. The Directive prohibits employers from asking applicants about their current or past pay. This is a hard ban across all member states.

Work of equal value is assessed against objective, gender-neutral criteria including skills, effort, responsibility, and working conditions. Comparators are not limited to the same employer and can extend to a 'single source' setting pay conditions.

Employers above the size threshold must publish their overall gender pay gap, the gap in complementary or variable components, the median gap, the proportion of women and men in each pay quartile, and the gap by categories of workers doing equal work or work of equal value.

If reporting shows a gap of at least 5% in any category of workers that cannot be justified on objective, gender-neutral grounds — and is not corrected within six months — the employer must conduct a joint pay assessment in cooperation with workers' representatives and implement remedial measures.

No. Employers cannot prevent workers from disclosing their pay for the purpose of enforcing the principle of equal pay. Contractual clauses restricting pay disclosure are unenforceable to that extent.

Workers have the right to request — and receive in writing within two months — information on their individual pay level and the average pay levels, broken down by sex, for categories of workers performing the same work or work of equal value.

Yes. Where a worker establishes facts from which it may be presumed that there has been direct or indirect pay discrimination, the burden shifts to the employer to prove there has been no such discrimination.

The Directive counts workers, not full-time equivalents. Part-time workers count as workers for threshold purposes; the specific method for calculating averages within reporting is set out in the Directive and national transposition.

The Directive sets minimum standards. Member states can maintain or introduce more favourable provisions. Countries with pre-existing pay-transparency rules (e.g. Spain, France, Portugal, Ireland) generally keep them and expand where the Directive goes further.

Member states must set penalties that are effective, proportionate and dissuasive. This includes fines, and may include exclusion from public procurement or public funding. The exact regime is set nationally during transposition.

Yes — if a company employs workers in the EU, those employment relationships are covered by the transposing national law where the work is performed, regardless of where the company is headquartered.