Takeaways

• EU Pay Transparency Directive 2023/970 imposes pay transparency requirements and equal pay reporting obligations on employers based in the EU or have employees located in the EU.
• EU Member States have until 06.07.26 to fully implement the Directive into their national law.
• Employers must proactively prepare to inform employees of their rights, disclose salary ranges in job postings, and justify pay differences using objective, gender-neutral criteria.

Article

September 18 marked International Equal Pay Day. This year’s International Equal Pay Day carries added significance for employers operating in the European Union as the clock ticks toward implementation of the EU Pay Transparency Directive (Directive (EU) 2023/970). The Directive imposes pay transparency requirements and equal pay reporting obligations on employers and applies to companies based in the EU or have employees located in the EU.

EU Member States have until June 7, 2026, to fully implement the Directive into their national law. Gathering the right data and running the required pay gap calculations for reporting can be a lengthy and time-consuming process. Now is the time for employers to start preparing.

New Legal Landscape

Employers with at least 100 employees face the Directive’s new obligations around salary transparency, employee access to pay data, and gender pay gap reporting.

Employers with at least 250 employees must publish their first reports by June 2027. Employers with 100–249...

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