PayAuditEU Pay Transparency Directive deadlines
Directive (EU) 2023/970 sets one transposition date and staggered reporting dates by employer size. Here they are, with the text of each article.
Transposition: 7 June 2026
Member States had to bring their national laws into force by this date. Until a country does, the directive does not by itself create duties between private employers and their workers; public employers may be exposed.
Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by 7 June 2026.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
250 or more workers: by 7 June 2027, then every year
The report covers the previous calendar year: the June 2027 report uses 2026 pay data.
Employers with 250 workers or more shall, by 7 June 2027 and every year thereafter, provide the information set out in paragraph 1 relating to the previous calendar year.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
150 to 249 workers: by 7 June 2027, then every three years
Same first date as the largest employers, with a three-year rhythm afterwards.
Employers with 150 to 249 workers shall, by 7 June 2027 and every three years thereafter, provide the information set out in paragraph 1 relating to the previous calendar year.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
100 to 149 workers: by 7 June 2031, then every three years
The smallest reporting band has four more years. The other duties apply earlier.
Employers with 100 to 149 workers shall, by 7 June 2031 and every three years thereafter, provide the information set out in paragraph 1 relating to the previous calendar year.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
Fewer than 100 workers
No reporting duty under the directive, but Member States may require it, and voluntary reporting cannot be prevented.
Member States shall not prevent employers with fewer than 100 workers from providing the information set out in paragraph 1 on a voluntary basis. Member States may, as a matter of national law, require employers with fewer than 100 workers to provide information on pay.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
What the report contains
Seven indicators, from the overall gender pay gap (a) to the gap in each category of workers (g). Indicator (g) goes to all workers and their representatives.
the gender pay gap between workers by categories of workers broken down by ordinary basic wage or salary and complementary or variable components.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
Employers shall provide the information referred to in paragraph 1, point (g), to all their workers and to the workers’ representatives of their workers. Employers shall provide the information to the labour inspectorate and the equality body upon request. The information from the previous four years, if available, shall also be provided upon request.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
Duties that don't wait for the report
Pay information before hiring, accessible pay-setting criteria and the right to information apply to every employer once national law is in force.
Applicants for employment shall have the right to receive, from the prospective employer, information about: (a) the initial pay or its range, based on objective, gender-neutral criteria, to be attributed for the position concerned; and (b) where applicable, the relevant provisions of the collective agreement applied by the employer in relation to the position. Such information shall be provided in a manner such as to ensure an informed and transparent negotiation on pay, such as in a published job vacancy notice, prior to the job interview or otherwise.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
Employers shall make easily accessible to their workers the criteria that are used to determine workers’ pay, pay levels and pay progression. Those criteria shall be objective and gender neutral.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
Workers shall have the right to request and receive in writing, in accordance with paragraphs 2 and 4, information on their individual pay level and the average pay levels, broken down by sex, for categories of workers performing the same work as them or work of equal value to theirs.Source: EUR-Lex, © European Union, https://eur-lex.europa.eu
Italy
D.Lgs. 96/2026 keeps the directive's thresholds and dates. It says the data are “collected” by those dates; the submission rules depend on a ministerial decree.
Le disposizioni di cui al presente articolo si applicano ai datori di lavoro con almeno cento dipendenti.Original text in Italian.
Source: Gazzetta Ufficiale della Repubblica Italiana, GU Serie Generale n. 125 del 1 giugno 2026 (codice redazionale 26G00112)
Per i datori di lavoro che occupano almeno duecentocinquanta dipendenti, i dati sono raccolti entro il 7 giugno 2027 e successivamente ogni anno. Per i datori di lavoro che occupano tra i centocinquanta e i duecentoquarantanove dipendenti, i dati sono raccolti entro il 7 giugno 2027 e successivamente ogni tre anni. Per i datori di lavoro che occupano tra i cento e centoquarantanove dipendenti, i dati sono raccolti entro il 7 giugno 2031 e successivamente ogni tre anni.Original text in Italian.
Source: Gazzetta Ufficiale della Repubblica Italiana, GU Serie Generale n. 125 del 1 giugno 2026 (codice redazionale 26G00112)
© European Union, https://eur-lex.europa.eu
General information, not legal advice. National rules can differ.