The first gender pay gap reports are due by June 7, 2027, which will cover 2026 data. This is required under the EU Pay Transparency Directive (Directive 2023/970), which member states must transpose into national law by June 7, 2026.
Mandatory reporting is phased in by company size, with employers of 150 or more staff in the first wave.
Reporting timeline by company size
- 250+ employees: report by June 7, 2027 (on 2026 data), then annually
- 150 to 249 employees: report by June 7, 2027 (on 2026 data), then every 3 years
- 100 to 149 employees: report by June 7, 2031 (on 2030 data), then every 3 years
- Under 100 employees: no mandatory reporting unless the member state imposes it. The salary range and pay secrecy rules still apply regardless of size.
The reporting period is the preceding calendar year, so the first report covers January to December 2026. Data collection needs to start now. The EU-wide average gap was 11.1% in 2024, according to Eurostat. If any group of workers shows a gap of 5% or more that can't be explained, a joint pay assessment has to be completed.
What must be reported
- The gender pay gap: difference between average gross hourly earnings of male and female workers, expressed as a percentage of male earnings
- The gap in variable components: bonuses, allowances, overtime, and other variable pay
- The median gap for both base and variable pay
- Proportion of female and male workers in each quartile pay band
Each member state chooses a national monitoring body that gets the reports, and employees and their representatives must be able to see them. In turn, the European Council page keeps updates of how member states are implementing the ruling.
What employers typically do now
As part of a broader effort to achieve pay equity, employers typically coordinate these procedures:
- Employers with 150+ staff often start collecting 2026 pay data now, broken down by gender and job category
- Map the workforce into "same work" or "work of equal value" categories, which is the unit of analysis rather than company-wide averages
- Do a quick gap analysis to find categories with more than 5% that need to be explained or fixed within 6 months.
- Remove pay secrecy clauses from all contracts, since they are void regardless of company size
Disclaimer:
This article informs. It does not advise on the law. When EU member states transpose the directive, they could set stricter deadlines than the minimum.
TL;DR
- First EU gender pay gap reports are due June 7, 2027, on 2026 data (employers with 150+ staff). 100 to 149 employees report from June 2031. Under 100: no mandatory reporting unless the member state requires it.
- Reports need to show the median gap between base pay and variable pay.
- Data collection for 2026 must start now. A joint pay review is required when there is a gap of 5% or more in any category.