Methodology

How we check sources

ValuGrade explains the EU Pay Transparency Directive for small employers. This page shows where our information comes from, how we check it and what it cannot do.

Last updated: 13 October 2026

Official sources first

For EU-wide rules we rely on the text of Directive (EU) 2023/970 as published on EUR-Lex and on material from the European Commission. For national implementation we only rely on official sources such as parliaments, ministries and official gazettes. News articles and commentary are never used as the only basis for a status.

Country status and check dates

Each of the 27 countries shows a status. A status counts as verified only when we opened an official source (parliament, ministry, official gazette or official consultation portal) that supports it; that source is linked and the date of the check is shown. If we could not confirm the status from such a source, the country is marked as not yet verified, without a check date. We never conclude that no draft exists only because we did not find one. There is no fixed review schedule: dates show when each source was actually checked.

No invented national rules

We do not add country-specific obligations until we can link them to an official national source. Where national law is not yet known, we describe the EU directive only and say so.

Limits

Legislation changes and national law may add or change requirements. Our check dates show when we last looked, not that nothing has changed since. Always check the official source before publishing job ads or answering a pay information request.

Corrections

Found an error or a newer official source? Email info@valugrade.eu with a link to the official document. We review every message and update the country page and its check date.

Salary band method

Midpoint from the median of the employer's own pay figures. Optional external benchmark: market benchmark only, blend own median and benchmark.

  • Band width per grade: 20%–60%. 30%, 30%, 40%, 40%.
  • Enter headcount and average annual pay by sex. ValuGrade flags a grade above 5% for review; this alone does not establish that a joint pay assessment is legally required.
  • A gap above 5% is a review signal. Article 10 includes additional conditions before a joint pay assessment is required, and national implementation must be checked.

EU-wide facts we rely on

  • Member States had to transpose the directive by 7 June 2026 (Article 34).
  • Applicants must receive information about the starting pay or its range in a way that allows informed negotiation, for example in a published vacancy notice, before the job interview or otherwise (Article 5).
  • Employers with 250 or more workers report on the gender pay gap by 7 June 2027 and then every year (Article 9).
  • Employers with 150 to 249 workers report by 7 June 2027 and then every three years (Article 9).
  • Employers with 100 to 149 workers report by 7 June 2031 and then every three years (Article 9).
  • Member States may require employers with fewer than 100 workers to report under national law (Article 9).
See all 27 countries

This tool provides structure and templates, not legal advice.

Next steps