Directive 2023/970: first reports for employers with 150+ workers are due 7 June 2027, covering the 2026 calendar year. The window is not ahead of you.
A regulation can set the deadline. It cannot define how an organisation will meet it.
Directive (EU) 2023/970 strengthens the principle of 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, but the reporting timetable continues to move.
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 reporting groups, readiness is already an operating question.
Reporting is the last step
The Directive treats pay as more than base salary. It includes complementary and variable components such as bonuses, allowances and benefits in kind. The evidence may be spread across payroll, HR, benefits and local records, with different definitions and levels of completeness.
“Work of equal value” also requires more than matching job titles. Categories must rest on objective, gender-neutral criteria such as skills, effort, responsibility and working conditions. Those choices determine which comparisons are made — and whether the result can be explained and defended.
An average gap of 5% or more within a category can trigger a joint pay assessment when it is not objectively justified and is not remedied within six months. Weak definitions or an incomplete evidence trail therefore become more than reporting defects.
The risk is not simply submitting late. It is reaching the deadline with figures the organisation cannot trace, explain or act on.
Where readiness breaks
- Definitions: what counts as pay, how comparable work is grouped and which rationale supports each choice.
- Evidence: where each required figure comes from, whether the underlying data is complete and how decisions remain traceable.
- Ownership: who resolves exceptions, approves interpretations and acts when the analysis exposes a gap.
These are connected decisions. Treating them as separate legal, data or reporting tasks leaves the organisation to reconcile them at the deadline.
What Ontzi builds
Ontzi turns the obligation into a reporting-ready operating model. We connect regulatory definitions to source data, make gaps and exceptions visible, establish decision ownership and preserve the rationale behind the result.
The immediate output is reporting readiness. The durable value is a repeatable capability: the organisation knows what each number means, where it came from, who owns it and how to respond.
The report is the deadline. The operating model is what makes it defensible.
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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.