EU Gender Pay Gap Reporting: Thresholds, Deadlines, and What to Report

EU Gender Pay Gap Reporting: Thresholds, Deadlines, and What to Report

If you employ people in the EU, gender pay gap reporting is no longer a "someday" problem. The transposition deadline for the EU Pay Transparency Directive passed on 7 June 2026, and the first reports are due in 2027. That gives you one full pay year — 2026 — to get your numbers right, because the figures you report next year describe how you pay people this year. The reporting rules are precise about who is covered, how often you file, and exactly which metrics you disclose. Miss a threshold or a deadline and you are not just out of compliance; you may trigger a mandatory joint pay assessment with your workforce. This guide breaks down the thresholds, the staggered deadlines, the specific metrics you owe, and the 5% rule that turns a reporting exercise into a remediation project.

TL;DR

• Employers with 250+ workers report annually; the first report is due 7 June 2027 on 2026 pay data.
• Employers with 150–249 workers report every three years, also starting 7 June 2027.
• Employers with 100–149 workers report every three years, starting 7 June 2031.
• Employers with fewer than 100 workers are not required to report under the Directive, though member states can go further.
• You report seven core metrics, including the mean and median gender pay gap and the gap in variable pay, broken down by category of workers.
• Any unjustified gender pay gap of 5% or more in a worker category that you do not fix within six months triggers a joint pay assessment with worker representatives.

Who has to report

Directive (EU) 2023/970 scales obligations by headcount, so the first thing to confirm is which band you fall into. Count workers, not full-time equivalents, and count at the level your national transposition law defines as the employer (often the legal entity).

A few practical notes. The bands are not interchangeable: a company with 250 workers reports four times as often as one with 240, so headcount near a threshold deserves a deliberate decision rather than a guess. Member states are free to impose stricter rules — some already require smaller employers to report — so your national law is the controlling document. And "worker" follows the EU's broad definition shaped by Court of Justice case law, which can pull in people you might not treat as employees for other purposes.

When you have to report

Two dates matter. The first reporting deadline is 7 June 2027 for every employer with 150 or more workers, and that report covers the 2026 calendar year. That is the catch most teams underestimate: the data you file in 2027 is generated by the pay decisions you make in 2026. If your job structure, pay ranges, or bonus rules are inconsistent today, you are already baking that inconsistency into your first official report.

Smaller covered employers get more runway. The 100–149 band does not file until 7 June 2031, then every three years after. But "more time" is not "no pressure." A clean report depends on a defensible pay structure, and building one takes months, not weeks.

A complicating reality in 2026: transposition across member states has been uneven. Only a handful of member states met the 7 June deadline, while large economies including Germany, France, Spain, and the Netherlands published drafts or are targeting entry into force in late 2026 or January 2027. Your exact filing format and any earlier national deadlines will come from local law, so track transposition in every country where you employ people. The Directive sets the floor; member states can raise it.

What you actually have to report

The Directive specifies the metrics — you do not get to choose your own. Covered employers report seven figures about pay between female and male workers:

• The mean gender pay gap.
• The median gender pay gap.
• The mean gender pay gap in complementary or variable components (bonuses, allowances, benefits).
• The median gender pay gap in those variable components.
• The proportion of female and male workers receiving variable or complementary pay.
• The proportion of female and male workers in each pay quartile.
• The gender pay gap by category of workers, broken down by ordinary basic salary and by variable components.

That last metric is the one that exposes problems. A company-wide average can look healthy while a specific category — say, mid-level engineers or regional sales managers — hides a real gap. The category breakdown is also where the Directive ties reporting back to job evaluation: a "category of workers" means employees performing the same work or work of equal value, and you are expected to group them using objective, gender-neutral criteria. If you cannot explain why two roles sit in the same category, your report is hard to defend.

Most headline figures are published or filed with a designated national monitoring body, while the category-level breakdown is made available to workers and their representatives. Either way, the numbers leave your building.

The 5% rule and the joint pay assessment

Reporting is not the end of the obligation — it is the trigger for the next one. If your report shows a gender pay gap of at least 5% in any category of workers, and you cannot justify that gap on objective, gender-neutral criteria, and you do not correct it within six months, you must carry out a joint pay assessment in cooperation with your workers' representatives.

A joint pay assessment is exactly what it sounds like: a structured, collaborative review of pay across the affected categories to find the causes of the gap and agree on remedial measures. It is not confidential housekeeping. Worker representatives are in the room, which means your pay rationale gets scrutinised by the people it affects. The way to avoid that scrutiny is not better messaging — it is a pay structure where any gap that survives is genuinely explained by factors like skill, responsibility, effort, and working conditions rather than gender.

This is the heart of why the Directive keeps circling back to job evaluation. A 5% gap that you can map to a transparent, point-factor assessment of the work is justifiable. A 5% gap you cannot explain is a remediation bill.

If you have not yet pressure-tested your categories and pay ranges, a pay equity audit is the fastest way to find the gaps that will show up in your first report — while you still have time to fix them quietly.

How to get ready before 2027

Start with structure, not spreadsheets. Reporting is a data exercise, but defensible reporting is a job-architecture exercise. Three moves matter most.

First, define your categories of workers using a consistent, gender-neutral method. If your "equal value" groupings are based on titles or history rather than the actual content of the work, fix that first — it determines every category-level number you report. Our guide to work of equal value walks through how the Directive expects you to compare roles.

Second, adopt a job evaluation method the regulator will recognise as objective. The Commission and EIGE point employers toward analytical, gender-neutral scoring of compensable factors — which is precisely what a gender-neutral job evaluation delivers. This is the evidence base that lets you justify a gap instead of remediating it.

Third, run the numbers early. Calculate your seven metrics on 2025 or partial-2026 data now, so the 2027 filing holds no surprises. For the full picture of every obligation the Directive creates, see our EU Pay Transparency Directive pillar guide.

Frequently asked questions

When is the first EU gender pay gap report due? 7 June 2027 for all employers with 150 or more workers, covering 2026 pay data. Employers with 100–149 workers file their first report by 7 June 2031.

How often do we have to report? Employers with 250 or more workers report annually. Employers with 150–249 and 100–149 workers report every three years.

Do small companies have to report? The Directive does not require employers with fewer than 100 workers to report. However, member states may impose stricter national rules, so check the law in each country where you employ people.

What counts as a "category of workers"? A group of employees performing the same work or work of equal value, defined using objective, gender-neutral criteria such as skill, effort, responsibility, and working conditions. This grouping drives your category-level pay gap figures.

What is the 5% rule? If a category of workers shows a gender pay gap of 5% or more that you cannot justify on objective, gender-neutral grounds and do not correct within six months, you must conduct a joint pay assessment with worker representatives.

Which metrics do we actually report? Seven: the mean and median gender pay gap, the mean and median gap in variable pay, the share of women and men receiving variable pay, the distribution of women and men across pay quartiles, and the gap broken down by category of workers.

Has every EU country implemented this yet? No. As of mid-2026 only a few member states transposed the Directive by the 7 June deadline; several large economies are still finalising national law. Your exact format and any earlier deadlines come from local transposition law.

What happens if we get the categories wrong? Poorly defined categories can mask real gaps and undermine your ability to justify them, which raises your risk of triggering a joint pay assessment. A defensible job evaluation method is the safeguard.

Gender pay gap reporting rewards employers who built a sound pay structure before the deadline and punishes those who waited. The metrics are fixed, the dates are set, and the 5% rule means a sloppy report can turn into a mandatory negotiation with your workforce. The good news is that the same work that makes you compliant — objective, gender-neutral job evaluation — also makes your pay decisions easier to defend year after year.

See how PointFactors scores every job against weighted compensable factors so your reporting categories and pay gaps are defensible from day one. Book a demo.

Justin Hampton is the founder and CEO of PointFactors.