Gender pay gap reporting: deadlines by company size

Reporting is the main part of the EU Pay Transparency Directive that depends on headcount (the other is an optional exemption from pay-progression criteria below 50 workers, Article 6(2)). Article 9 of Directive (EU) 2023/970 sets the thresholds and the first dates. Everything else, such as pay information for applicants and the right of workers to ask about pay, applies to employers of every size.

The thresholds and first dates

• 250 or more workers: first report by 7 June 2027, then every year.
• Between 150 and 249 workers: first report by 7 June 2027, then every three years.
• Between 100 and 149 workers: first report by 7 June 2031, then every three years.
• Fewer than 100 workers: no reporting duty under the directive. Member states may require it under national law.

Each report covers the previous calendar year. Because national implementation decides the reporting channel and practical details, check the country page for your country before planning.

What goes into the report

Article 9 lists the indicators. In plain terms, employers report:

• the gender pay gap, as a mean and as a median;
• the gap in complementary or variable components (for example bonuses), mean and median;
• the share of female and male workers receiving such components;
• the share of female and male workers in each quartile pay band;
• the gap between female and male workers by category of workers, split by ordinary basic pay and complementary or variable components.

The last indicator is the demanding one. It needs categories of workers doing the same work or work of equal value, which is exactly what a job evaluation produces. Our guide to gender-neutral job evaluation explains how to build them.

The 5% trigger

If the report shows a gap of at least 5% in any category of workers, the employer has not justified it with objective, gender-neutral criteria, and has not remedied it within six months, Article 10 requires a joint pay assessment together with workers' representatives.

Why a 40-person company should still care

Under 100 workers you do not report under the directive, but the data behind the report is the same data you need to answer an individual pay information request (Article 7). If a worker asks for the average pay of women and men in their category, you need categories and clean pay data anyway.

You can test your numbers with the free gender pay gap calculator, and check which duties apply to your size with the applicability checker.

Sources

The dates and indicators above come from Articles 9 and 10 of Directive (EU) 2023/970 on EUR-Lex. How we check facts and country statuses is explained on our methodology page.