Pay Transparency Directive (PTD) key dates and indicative timeline of practical actions*

* based on the key dates contained in the PTD only, local variations may apply

The Pay Transparency Directive sets out strong standards and will have significant implications for employers with operations in the EU. All companies, regardless of their size or sector, will need to comply with at least some aspects of the Pay Transparency Directive once implemented locally by 7 June 2026. All employers with 100 or more workers will have reporting requirements from 7 June 2027 onwards, with the timing and frequency of reporting depending on the size of the workforce. Different thresholds/dates may be mandated by national law. Although the deadlines still seem some way off, the requirements will represent a significant step change for most organisations, which will require careful early planning. All companies with operations in the EU will need to start taking steps now to proactively ensure that they are ready for the requirements of the Directive. Set out below is an indicative timeline of some of the key practical steps.

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Key dates

Practical actions

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Key dates

Practical actions

Establish a team

Identify your cross-functional Pay Transparency team, including legal, compliance, HR and reward leads. Consider whether external legal or other expert assistance is needed.

6 June 2023

PTD in force.

Know the requirements

Identifying how the requirements of the Pay Transparency Directive compare to existing local law and current practices will be an important early step for companies, as well as then tracking the implementation of the Directive and any enhancements in each EU country of operation. Some countries beyond the EU are also starting to legislate for pay transparency, so it will be important for companies seeking to achieve a global approach to be aware of those wider developments too.

Know your data

Knowing what information already exists within a company around its headcount by legal entity and country, its pay and pay practices, where that information is held and who has access to it, as well as any steps already being taken to analyse or report the data, will be key to establishing a strategy to close any areas where data is lacking and ensuring legal compliance.

Data analysis

Analyse your gender pay data, including any pay gap and its causes. Ensure gender-neutral criteria are in place to determine worker’s pay, pay levels and pay progression. Establish a plan to take actions to close any gap.

Recruitment process adjustments

All employers should review and, where necessary, update recruitment practices to ensure the disclosure of initial pay / pay range and to avoid inquiring about a candidate’s pay history.

Training and policies

Train managers, recruitment teams and HR staff. Companies will need to take steps to ensure that those responsible for compliance and implementation are fully appraised of the legal requirements and that the new obligations are reflected in policies and procedures.

Establish a communication strategy

Establish a plan to:

inform workers annually about their right to request and receive 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;
communicate the information contained in gender pay gap reports, including: - making available to workers prescribed information on the gender pay gap between workers by categories of workers broken down by ordinary basic wage or salary and complementary of variable components. - making prescribed information in the report publicly available; - communicating the prescribed information in the report to the relevant authority.

Pay data compilation in preparation for reporting by employers with 150+ workers

All employers with 150 or more workers will have reporting requirements starting from 7 June 2027, relating to the previous calendar year. Reporting data should start to be compiled from at least 7 June 2026.

7 June 2026 PTD transposition deadline

Member States have until 7 June 2026 to bring into force laws, regulations and administrative provisions necessary to comply with the Pay Transparency Directive.

Employers with 150+ workers – draft reports

Reports should cover prescribed gender pay gap information, including the gender pay gap, the mean and median pay gaps, the proportion of men and women receiving complementary or variable components of pay, the proportion of men and women within each quartile pay band, and the gender pay gap by categories of workers, broken down by ordinary basic wage or salary and complementary or variable components.

Employers with 150+ workers – finalise report

Accuracy of the report to be confirmed by the employer’s management, after consulting with workers’ representatives.

7 June 2027 - PTD reporting obligation starts for employers with 150+ workers

All employers with 150 or more workers will have reporting requirements starting, with the frequency of reporting depending on the size of workforce.

Potential joint pay assessment requirements

An obligation to carry out a joint pay assessment will arise where:

there is a pay gap of 5% or more in any category of workers;
such a difference cannot be objectively justified – by reference to gender neutral reasons; and
the employer has not put right the unjustified difference within 6 months of reporting it.

7 June 2028

Second annual PTD reporting for employers with 250+ workers.

Potential joint pay assessment requirements

An obligation to carry out a joint pay assessment will arise where:

there is a pay gap of 5% or more in any category of workers;
such a difference cannot be objectively justified – by reference to gender neutral reasons; and
the employer has not put right the unjustified difference within 6 months of reporting it.

7 June 2029

Third annual PTD reporting for employers with 250+ workers.

Potential joint pay assessment requirements

An obligation to carry out a joint pay assessment will arise where:

there is a pay gap of 5% or more in any category of workers;
such a difference cannot be objectively justified – by reference to gender neutral reasons; and
the employer has not put right the unjustified difference within 6 months of reporting it.

7 June 2030

Fourth annual PTD reporting for employers with 250+ workers
Second report for employers with 150-249 workers.

Pay data compilation in preparation for reporting by employers with 100-149 workers

All employers with 100-149 workers will have reporting requirements starting from 7 June 2031, relating to the previous calendar year. Data should start to be compiled from at least 7 June 2030.

Employers with 100-149 workers – draft reports

Potential joint pay assessment requirements

An obligation to carry out a joint pay assessment will arise where:

there is a pay gap of 5% or more in any category of workers;
such a difference cannot be objectively justified – by reference to gender neutral reasons; and
the employer has not put right the unjustified difference within 6 months of reporting it.

Employers with 100-149 workers – finalise report

Accuracy of the report to be confirmed by the employer’s management, after consulting with workers’ representatives.

7 June 2031

PTD reporting obligation starts for employers with 100-149 workers
Fifth annual PTD reporting for employers with 250+ workers

Potential joint pay assessment requirements

An obligation to carry out a joint pay assessment will arise where:

there is a pay gap of 5% or more in any category of workers;
such a difference cannot be objectively justified – by reference to gender neutral reasons; and
the employer has not put right the unjustified difference within 6 months of reporting it.

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