Your 2026 payroll is already your first EU pay-gap report

The EU Pay Transparency Directive (2023/970) had to be written into national law by June 7, 2026. Only four member states made it on time: Italy, Malta, Slovakia and Lithuania. Greece followed, with its main provisions taking effect on November 1. Most of the rest have draft bills, partial measures or nothing published yet. On May 22, 2026, the Commission said it "does not envisage" including the directive in any simplification or "stop-the-clock" package.

That combination has led many multinationals to conclude they have time. They have less than they think.

Why "not transposed yet" doesn't mean "not yet"

The directive's reporting dates are fixed in the directive itself. Employers with 250 or more workers report every year, and those with 150 to 249 report every three years, with the first reports for both due by June 7, 2027. Employers with 100 to 149 workers start on June 7, 2031. Each report covers the previous calendar year.

So the data for your first report is the payroll you are running right now. When Germany, France or the Netherlands finally pass their laws, they will ask about 2026. Some countries already add earlier steps: Slovakia required compliant pay structures by July 31, 2026, and Lithuania requires a documented pay system by December 31, 2026.

The reporting year started on January 1. The national laws are catching up to it.

The 5% trigger

The part that worries reward teams most is Article 10. If your report shows a gender pay gap of 5% or more in any category of workers, you can't justify it with objective, gender-neutral criteria, and you don't fix it within six months, you must run a joint pay assessment with workers' representatives. "Category of workers" means people doing the same work or work of equal value, which is a job-architecture question before it is a pay question. If your job levels don't map cleanly to comparable work, you can't defend a gap you can't define.

What already applies at hiring

Where the directive is in force, and soon everywhere in the EU, the candidate-facing rules change your recruiting process:

• Tell candidates the starting pay or pay range before the interview, or in the job ad.
• Stop asking about current or past pay.
• Use gender-neutral job titles and vacancy notices.
• Make the criteria for pay and pay progression accessible to employees (countries may exempt employers under 50 from the progression rule).
• Answer an employee's request for pay information within two months, and remind everyone of that right every year.

Where the big countries stand

Trackers maintained by law firms and reward vendors differ in the details, but the picture in mid-October is consistent. Germany has not published a draft, and reporting there may not start until 2028. France's bill is in the Senate, with a vote expected before spring 2027. The Netherlands has scheduled its plenary debate for January 11, 2027, so its January 1 target will slip. Denmark's bill would take effect March 1, 2027, and Finland targets January 1, 2027. Ireland has not prioritized its bill, and Sweden has asked for more time. None of that moves the directive's reporting dates.

The plan for Q4 2026 to Q1 2027

1. Run a privileged pay-equity audit on 2026 data, country by country and by category of comparable work. Do it with counsel so findings you can't yet explain stay protected while you fix them.
2. Repair the job architecture. Define categories by skills, effort, responsibility and working conditions. This is the foundation of every other step.
3. Fix the hiring pipeline EU-wide. Pay ranges in job ads, salary-history questions removed from ATS forms and recruiter scripts, gender-neutral templates.
4. Stand up the pay-information request process with a two-month service level and an annual reminder to employees.
5. Close unexplained gaps of 5% or more before you report them. A gap fixed before reporting is a budget line; a gap reported and left open is a joint pay assessment.
6. Brief works councils early. They will be your partners in any joint pay assessment.

The countries that missed the deadline bought themselves time. They didn't buy any for you.

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