EU and Malta compliance

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.

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The 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.

The new duties

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.

The reporting timeline

When employers must report, by size

Employer sizeFirst gender pay-gap reportFrequency
250 or more workersFrom 7 June 2027, on 2026 dataAnnual
150 to 249 workersFrom 7 June 2027Every three years
100 to 149 workersFrom 7 June 2031Every three years
Fewer than 100 workersNo mandatory pay-gap reportThe other transparency duties still apply
The test that matters

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.

How Auren trains it

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.

Questions

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.

Related at Auren

Go deeper

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.

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