EU Pay Transparency Directive: 2027 Guide for Employers

20267 June: transposition deadline

20277 June: first report for employers with 150+ workers

5%Gap within a category that can trigger a joint pay assessment

11.1%EU unadjusted gender pay gap (gross hourly earnings, 2024, Eurostat)

This guide covers the core rules, where transposition stands, what it means for companies with operations in both Turkey and the EU, and how HR teams can prepare now.

What is the EU Pay Transparency Directive?

Directive (EU) 2023/970 was adopted on 10 May 2023 and published in the Official Journal on 17 May 2023. Its goal is to make the principle of equal pay for equal work, or work of equal value, between women and men enforceable in practice, through transparency duties and stronger remedies.

It applies to public and private sector employers in EU member states. It covers everyone with an employment contract or relationship, and job applicants. Pay is defined broadly: the basic wage plus any other consideration in cash or in kind, including bonuses, allowances and other complementary or variable components.

Because it is a directive, the obligations reach employers through each member state's implementing law. Details such as penalty levels, the reporting body and the reporting format can therefore differ from country to country.

Why it matters for companies operating in Turkey

The directive does not apply to employment relationships in Turkey. It still reaches Turkish and Turkey-based businesses in two ways, and a similar principle already exists in Turkish law:

Turkish companies with EU entities: a subsidiary or branch that employs staff in an EU country is subject to that country's law. Thresholds and reporting duties are assessed for that employer.
EU groups with Turkish subsidiaries: groups that run a common pay framework may ask their Turkish entities for comparable pay and grading data.
Existing Turkish law: Article 5 of the Turkish Labour Law (No. 4857) already states that a lower wage may not be agreed for the same work or work of equal value because of sex. The same article provides compensation of up to four months' wages and shifts the burden of proof to the employer once the worker shows a strong likelihood of a breach. The directive goes a step further by backing that principle with pay data and regular reporting.

The pay gap is on the agenda in Turkey too. According to "Women in Statistics in Türkiye 2024", a joint TurkStat and UN Women publication, the gender pay gap in 2023 was 17.4% among higher education graduates and 16.7% among high school graduates. TurkStat measures average gross wages while Eurostat uses gross hourly earnings, so the two figures are not directly comparable.

Transparency before hiring (Art. 5)

Applicants receive the initial pay or its range. Employers may not ask applicants about their pay history in current or previous jobs.

Pay-setting criteria (Art. 6)

The criteria used to set pay, pay levels and pay progression must be easily accessible to workers. Member states may exempt employers with fewer than 50 workers from the pay progression part.

Right to information (Art. 7)

Workers have the right to request and receive in writing their own pay level and the average pay levels, broken down by sex, of colleagues doing the same work or work of equal value. Employers must reply within two months, and workers cannot be prevented from disclosing their pay to enforce equal pay.

Pay gap reporting (Art. 9)

Employers with 100 or more workers report seven indicators, including the mean and median pay gap and the share of women and men in each quartile pay band. The timeline depends on headcount.

Joint pay assessment (Art. 10)

For employers subject to reporting, if the average pay level of women and men in any category of workers differs by at least 5%, the gap is not justified by objective, gender-neutral criteria and it is not remedied within six months of submitting the report, a joint pay assessment with worker representatives is required.

Burden of proof and remedies (Art. 16, 18, 21)

Once a worker establishes facts suggesting discrimination, the employer must prove there was none. Compensation, including full back pay and related bonuses, cannot be capped in advance, and limitation periods are at least three years.

Pay gap reporting timeline

Reporting starts in stages based on headcount. Under the directive, the first report for employers with 250 or more workers is due by 7 June 2027 and covers the previous calendar year, 2026. In other words, the data you will report is being created now.

Number of workers	First report	Frequency
250 or more	7 June 2027	Every year
150–249	7 June 2027	Every three years
100–149	7 June 2031	Every three years
Fewer than 100	Not required by the directive; member states may require it	Voluntary reporting allowed

This is the directive's timetable. National laws may set different dates or methods: in Lithuania, employers submit pay data to the social insurance fund (Sodra) from 1 January 2027, and Sodra calculates the indicators and first shares them with employers of 150 or more workers by 1 March 2028. Czechia's draft starts pay gap reporting on 1 January 2028.

The seven reporting indicators

Mean gender pay gap
Mean gender pay gap in complementary or variable components
Median gender pay gap
Median gender pay gap in complementary or variable components
Share of female and male workers receiving complementary or variable components
Share of female and male workers in each quartile pay band
Gender pay gap by category of workers

Categories of workers must be built on objective, gender-neutral criteria such as skills, effort, responsibility and working conditions. Your job evaluation and grading structure therefore has a direct effect on how reliable the report is.

Transposition status (end of September 2026)

The deadline was 7 June 2026, and only four member states (Slovakia, Italy, Lithuania and Malta) adopted their transposing laws on time. According to law firm and industry trackers as of late September 2026:

Transposed: Slovakia, Italy, Malta and Lithuania on time, and Greece through a law published on 6 July 2026. In Greece the main obligations apply from 1 November 2026, and Lithuania phases in some obligations from 2027.
Partial measures: Poland's recruitment transparency rules have applied since 24 December 2025, with a full act still pending. Estonia has passed a partial law, with no further legislative proceedings currently under way, and in Belgium only regional public-sector rules are in place so far, with no federal private-sector bill yet.
Bills in progress: in the Netherlands, plenary debates are scheduled for December 2026 and January 2027, which puts the government's 1 January 2027 target in doubt. France and Czechia have government bills that are at, or about to enter, the parliamentary stage. In Denmark, the bill tabled in February 2026 lapsed with the June election and has to be reintroduced.
Behind schedule: Germany has no law in force and the government bill has not yet passed cabinet. In March 2026 Sweden's government said it would not submit a bill for now and would push for the directive to be postponed and renegotiated. Ireland's main bill is still being drafted.

The picture is changing quickly. Confirm the current national rules with local counsel in every EU country where you employ staff.

Late transposition is not a reason to wait. Where laws are passed, obligations start quickly, and under the directive 2027 reporting relies on 2026 data.

Preparation checklist for HR teams

Count workers for each EU employing entity and identify which reporting timeline applies.
Bring pay data into one place, including base pay, bonuses, allowances and benefits.
Group roles by skills, effort, responsibility and working conditions, and make pay grades explicit.
Set the starting pay or range you will share with candidates for each role, and remove pay history questions from application forms and interview guides.
Turn your pay and pay progression criteria into a policy that workers can access.
Review any pay secrecy clauses in contracts and policies with your legal team.
Calculate mean and median gender pay gaps internally and document the reasons for any category above 5%.
Remind workers every year of their right to pay information, and set up a process and an owner to answer requests within the national deadline (two months at most under the directive, shorter in some countries).

Compensation Review

Run raises and salary revisions through approval workflows and keep decisions on record with a budget and cost view. Explore Compensation Review

Reporting

Combine gender, department, position and pay data in custom reports and export them to Excel to run your pay gap analysis. Explore Reporting

AI-Powered ATS

Record a minimum and maximum salary on hiring requests and job postings so the range you share with candidates comes from one source, and work with pay expectations instead of pay history. Explore the AI-Powered ATS

Performance Review

Link pay progression to documented, objective criteria with KPI and OKR-based reviews. Explore Performance Review

Does the EU Pay Transparency Directive apply to employees in Turkey?

No. It applies to employers in EU member states, and obligations arise under each country's implementing law. If you have a company or branch employing staff in the EU, that employer is subject to local law. In Turkey, Article 5 of the Labour Law already prohibits agreeing a lower wage for the same work or work of equal value because of sex.

When is the first gender pay gap report due?

Under the directive, employers with 250 or more workers report by 7 June 2027 on calendar year 2026, then every year. Employers with 150–249 workers also report by 7 June 2027, then every three years. Employers with 100–149 workers report by 7 June 2031, then every three years. Because transposition is late, national laws may set different dates: in Lithuania the first indicators reach employers in 2028, and Czechia's draft applies reporting from 1 January 2028.

Do job ads have to include a salary range?

The directive requires applicants to receive the initial pay or its range. Whether that must appear in the job ad, before the interview or in another way can depend on national law. Employers also may not ask applicants about their pay history.

What is the 5% rule?

It applies to employers that must report their pay gap. If the report shows a difference of at least 5% in average pay levels between women and men in any category of workers, and the employer cannot justify it with objective, gender-neutral criteria, the gap must be remedied within six months of submitting the report. If it is not, a joint pay assessment with worker representatives is required.

Which EU countries have transposed the directive?

According to trackers updated at the end of September 2026, Slovakia, Italy, Malta, Lithuania and Greece have transposed it. Poland, Estonia and Belgium have partial measures. Most others, including Germany, France and the Netherlands, are still drafting or debating bills, while Sweden has said it will not table a bill for now. Check the latest position with local counsel.

Does "pay" mean base salary only?

No. Pay covers the basic wage and any other consideration in cash or in kind, such as bonuses, allowances and benefits. Reporting includes separate indicators for complementary and variable components.

Sources

This page is for general information and is not legal advice. Rely on national legislation and official sources for country-specific obligations.

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