The EU Pay Transparency Directive: what employers must do
EU member states must transpose the Pay Transparency Directive (2023/970) into national law by 7 June 2026. Employers with EU staff face new pay-transparency duties and gender pay-gap reporting, starting with the largest from June 2027. This is what HR has to action, and how to train for it.
Talk to usThe 7 June 2026 deadline
Member states, including Malta, must have the Directive in national law by 7 June 2026. The duties land on employers as each country transposes.
Who reports, and when
Gender pay-gap reporting phases in by size: employers with 250 or more workers first, from June 2027, smaller employers following through to 2031.
What HR must change
Job ads, hiring processes, pay structures and reporting all change. The work starts well before the first report is due.
Five things HR has to put in place
1. Pay transparency before hiring
Publish the starting pay or pay range for a role on objective, gender-neutral criteria, and stop asking candidates for their pay history.
2. The right to information
Workers can ask for their own pay level and the average pay by sex for comparable work, and you must respond, normally within two months.
3. Gender pay-gap reporting
Report the gender pay gap on a set schedule by employer size, from 7 June 2027 for the largest employers on 2026 data.
4. Joint pay assessment
Where reporting shows a gap of 5 percent or more that you cannot justify on objective grounds, you must run a joint pay assessment with worker representatives.
5. Objective pay structures
Build pay and progression structures on objective, gender-neutral criteria so equal work and work of equal value can actually be assessed.
When employers must report, by size
| Employer size | First gender pay-gap report | Frequency |
|---|---|---|
| 250 or more workers | From 7 June 2027, on 2026 data | Annual |
| 150 to 249 workers | From 7 June 2027 | Every three years |
| 100 to 149 workers | From 7 June 2031 | Every three years |
| Fewer than 100 workers | No mandatory pay-gap report | The other transparency duties still apply |
This is an HR systems change, not a poster
Pay transparency is not a single announcement. It reaches into how you advertise roles, how you set and explain pay, what you tell employees who ask, and what you publish. The employers who cope are the ones whose HR teams understood the duties early and trained their managers to apply them, not the ones who read the Directive the week the first report was due.
Foundation to Advanced, with a Malta variant
1. Foundation for managers
Line managers learn the new rules on job ads, salary-history questions and answering pay queries, so the front line does not create risk.
2. Intermediate for HR
HR and reward teams learn to build objective pay structures, run the reporting, and handle information requests within the deadlines.
3. Advanced for leads
Compliance and reward leads get the audit-grade level on joint pay assessments, the 5 percent threshold, and enforcement exposure.
4. Malta and EU variants
Where national transposition differs, you get the right version, with a Maltese variant for employers operating in Malta.
EU Pay Transparency Directive, common questions
When does the EU Pay Transparency Directive take effect?
Member states must transpose Directive 2023/970 into national law by 7 June 2026. The European Commission has confirmed that deadline is unchanged. The first gender pay-gap reports for the largest employers follow from 7 June 2027, on 2026 data.
Which employers have to report the gender pay gap?
Reporting phases in by size. Employers with 250 or more workers report annually from 7 June 2027, employers with 150 to 249 every three years from 2027, and employers with 100 to 149 every three years from 2031. Employers under 100 are not required to report, but the other transparency duties still apply.
Does the Directive apply in Malta?
Yes. Malta, as an EU member state, must transpose the Directive into national law by 7 June 2026, so Maltese employers are in scope. Auren provides a Maltese variant where the national rules differ.
What is the 5 percent pay-gap rule?
Where pay-gap reporting reveals a difference in average pay between women and men of at least 5 percent for a category of work that the employer cannot justify on objective, gender-neutral criteria, the employer must carry out a joint pay assessment with worker representatives.
Go deeper
- EU Pay Transparency, Foundation course
- Pay Transparency, HR practical guide
- The Course Catalogue
- Customisation and Advisory
Get HR ready before the deadline
Tell us where your EU staff sit and your headcount, and we will map the right levels and the Malta variant to your team.
Talk to us
Compliance, Done Right.
Auren Institute is a compliance training partner for HR and L&D leaders at SMEs and mid-market employers in the UK and Malta. Eleven compliance domains. Three levels in each. UK and Maltese variants where the law differs. Updated within 30 days of legislative change.
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