Directive 2023/970: first reports for employers with 150+ workers are due 7 June 2027, covering the 2026 calendar year.
Directive (EU) 2023/970 requires equal pay for equal work — and work of equal value — through transparency, reporting and stronger remedies. Member states were due to transpose it by 7 June 2026. National implementation remains uneven. The reporting timetable does not wait.
Employers with 250 or more workers, and those with 150 to 249, provide their first gender pay gap information by 7 June 2027, using 2026 calendar-year data. Employers with 100–149 workers follow in 2031. For the first groups, 2026 is already the data year.
What the report rests on
The Directive treats pay as more than base salary. It includes complementary and variable components: bonuses, allowances and benefits in kind. That evidence usually sits across payroll, HR, benefits and local records, with different definitions and different holes.
“Work of equal value” is not a job-title match. Categories have to rest on objective, gender-neutral criteria such as skills, effort, responsibility and working conditions. Those choices decide which comparisons are made, and whether anyone can explain the result.
An average gap of 5% or more within a category can trigger a joint pay assessment if it is not objectively justified and is not remedied within six months. Weak definitions or an incomplete trail leave the organisation with a number it cannot stand behind.
Where it breaks
- Definitions: what counts as pay, how comparable work is grouped, and the rationale for each choice.
- Evidence: where each required figure comes from, whether the underlying data is complete, and how a decision stays traceable.
- Ownership: who resolves exceptions, who approves an interpretation, and who acts when the analysis shows a gap.
What we build
We map the Directive’s definitions onto the organisation’s actual sources. Gaps and exceptions stay visible. Someone owns each decision, and the rationale travels with the number.
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This field note is general information, not legal advice. National requirements, dates and remedies should be checked in the law applicable to each employer.