EU Pay Transparency Directive 2023/970

The 2026 Deadline Is Closer Than You Think.

EU Directive 2023/970 requires companies with 100+ employees to report pay data by June 2027. The preparation window is now. Companies that wait face rushed, costly remediation — or fines.

Key Dates You Cannot Miss

2026
EU Directive Transposition Deadline

All EU member states must have transposed the directive into national law by June 2026.

2027
First Reporting Deadline (150+ employees)

Companies with 250+ employees report annually; 150–249 every 3 years. First report due 7 June 2027.

2031
Reporting Deadline (100–149 employees)

Companies with 100–149 employees report every 3 years, starting 7 June 2031. Smaller employers are not required by the directive itself.

What the Directive Requires

Pay Transparency on Hiring

From 2026, job postings must include or provide pay information to candidates. Employers cannot ask for salary history.

Individual Pay Information Rights

Employees have the right to request information on average pay levels by gender for comparable roles.

Pay Equity Reporting

Companies must report the gender pay gap by category of workers, including adjusted (WIF-based) and unadjusted figures.

Joint Pay Assessment

If the report shows a pay gap of 5% or more not justified by objective factors, a joint pay assessment with employee representatives is mandatory.

Our 4-Step Compliance Approach

01

Data Audit

Clean and structure your payroll and HR data to meet the Directive's job category and WIF requirements.

02

Gap Analysis

Calculate your current adjusted and unadjusted gender pay gap per job category. Identify exposure before regulators do.

03

Remediation Planning

For gaps above 5%, develop a documented, defensible remediation plan — salary adjustments, promotion criteria, or policy changes.

04

Report Generation

Produce the board-ready and authority-ready pay equity report. CompLens automates Article 9 reporting in under 5 minutes.

CompLens

Automate Compliance with CompLens

Our CompLens tool handles the entire EU Pay Transparency reporting process — data import, WIF-adjusted gap calculation, and one-click report generation. 100% GDPR-compliant, EU servers.

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Frequently Asked Questions

Does the directive apply to non-EU companies with EU operations?
Yes. Any company with employees in EU member states must comply with the transposed national legislation, regardless of where the parent company is headquartered.
What counts as a 'comparable role' for pay gap calculation?
The Directive uses a broad definition: work of 'equal value' based on factors like skills, effort, responsibility, and working conditions. This requires a formal job evaluation methodology — not just job title comparison.
What are the penalties for non-compliance?
Member states must provide 'effective, proportionate, and dissuasive' penalties. Based on early transposition drafts, fines range from €10,000 to several hundred thousand euros per violation, plus litigation risk from individual employee claims.

Start Your Compliance Journey

A pay equity gap analysis takes 2–4 weeks. The sooner you know your exposure, the lower the remediation cost.

Get a Gap Analysis