Who must report, and when
Last reviewed 2026-10-16
Article 9 size bands and the Directive dates for a first gender pay-gap report: 7 June 2027 and 7 June 2031.
Article 9 · Article 34
The Directive sets employer size bands
Article 9 tells Member States to require gender pay-gap information from employers with 100 workers or more. Employers with 250 workers or more report every year. Employers with 150 to 249 workers report every three years. Employers with 100 to 149 workers report every three years. Employers with fewer than 100 workers are outside that Article 9 reporting duty. Member States may still extend reporting below 100. That extension would be national law.
First dates in the Directive
Article 9 sets the first report at 7 June 2027 for employers with 150 workers or more, and at 7 June 2031 for employers with 100 to 149 workers. Those dates are in the Directive. They bind a private employer when the Member State has transposed the duty. Article 34 requires Member States to transpose by 7 June 2026. A missed transposition date does not by itself create the employer duty.
What “worker” means here
The Directive uses “workers”, including people in an employment relationship as national law and the case law of the Court of Justice define it. This page does not convert that into a full-time-equivalent formula. Count rules, if a State publishes them, belong on that State’s country page and in the statute.
Related
Source
Directive (EU) 2023/970 on pay transparency (adopted 2023-05-10)
Update log
- 2026-10-16 — First published from Article 9 and Article 34 of Directive (EU) 2023/970.
Informational only. This is not legal advice and not a statement of national law. Statutory claims cite Directive (EU) 2023/970 and carry a last-reviewed date. A Member State duty exists only when that State’s law says so. See the country pages for a dated status snapshot.