What the Pay Transparency Directive changes
Directive (EU) 2023/970 applies across the Union; each member state sets its own implementation. These are the five things it asks of you. The dates are the Dutch ones, as an example.
Short answer. Directive (EU) 2023/970 requires employers to make pay explainable: gender-neutral job evaluation, pay information before the pay talk, a right to pay information for employees and, for larger employers, periodic pay gap reporting. In the Netherlands it is implemented by the Wet implementatie Richtlijn loontransparantie mannen en vrouwen (bill 36949), with intended entry into force on 1 January 2027; employers with 150 or more employees report for the first time by 7 June 2028, on 2027.
Job evaluation on objective criteria
Every employer, whatever its size, must be able to compare roles on objective, gender-neutral criteria. Article 4 of the Directive names four that must always be included: skills, effort, responsibility and working conditions. Relevant soft skills must not be undervalued, and the criteria are agreed with workers' representatives where they exist.
Simply putting roles in order of weight is not enough, according to the guidance of the Dutch Ministry of Social Affairs. This is the foundation under the other four points: without comparable roles, you cannot demonstrate work of equal value.
Transparency before hiring
You share the salary or salary range before the first discussion of terms, for instance in the vacancy. And you may no longer ask candidates about their pay history.
This applies in principle to employers of any size, including those with no reporting duty.
Information rights for employees
Employees gain the right to information about their own pay level and about average pay levels for colleagues doing equal or equivalent work, broken down by sex.
You need a process for that, and you must tell employees the right exists. Clauses preventing employees from discussing pay are not permitted.
Reporting on the pay gap
Larger employers report periodically on pay differences between women and men. In the Netherlands, employers with 150 or more employees report by 7 June 2028 on calendar year 2027; those with 100 to 149 by 7 June 2031.
Thresholds and dates differ per member state. Check what applies in the countries where you employ people.
The 5 per cent threshold
If reporting shows an unexplained difference of 5 per cent or more within a category of workers, and it is not corrected within six months, a joint pay assessment with workers' representatives follows.
Five per cent is not a tolerance level. A smaller difference you cannot objectively explain may still be unjustified.
Three things to arrange now
The 5% trigger
Where an unexplained pay difference within a category of workers reaches 5% or more, has no objective justification and is not corrected within six months, a joint pay assessment with employee representatives follows. Note: 5% is not a tolerance threshold. Smaller unjustified differences must be addressed as well. The check tests whether you can calculate this and whether you have a scenario ready.
Employee representation
Pay transparency touches trust and industrial relations. In a joint pay assessment, employee representatives are a required partner. The check looks at whether representatives are structurally involved in pay policy. Early involvement prevents that conversation from happening under time pressure.
Board reporting
The report includes an executive summary: score, main risks, first measures and the decision requested. Ready to use in a management meeting, supervisory board or audit committee, so ownership and budget are assigned rather than left open.
From Directive to reporting duty
The Directive sets the framework. Each member state sets its own dates in national law.
Directive adopted
Directive (EU) 2023/970 on pay transparency and enforcement of equal pay enters into force.
Transposition deadline
Member states were required to transpose the Directive into national law by 7 June 2026. Several states, including the Netherlands, did not meet that deadline.
National implementation under way
Implementing legislation is in progress across the EU. Obligations, thresholds and dates take effect through the national law that applies to your organisation.
Transparency obligations apply
Pay ranges when recruiting, the ban on asking about pay history, accessible pay criteria and employee information rights come into effect as national laws enter into force.
First pay gap reports
Larger employers report on the gender pay gap, with the first reporting year and deadline set nationally. In the Netherlands, for example, the bill provides for a first report by 7 June 2028 covering calendar year 2027 for employers from 150 people.
Status based on public sources, August 2026. National implementing legislation is still in progress and may change. Check the position for your own country and legal entity.
18 September: equal pay for work of equal value
The United Nations has marked 18 September as International Equal Pay Day since 2019. It is a fixed, symbolic date that recognises the ongoing effort towards equal pay for work of equal value, worldwide.
Globally, women are paid around 20 per cent less than men. International Equal Pay Day is not calculated from that figure; it is a fixed day for reflection and action, supported by UN Women and the International Labour Organization.
Read more on un.orgNational Equal Pay Days are calculated, and therefore move
Many countries also mark their own Equal Pay Day: the point in the year from which women effectively work unpaid, given the average pay gap. Because it is derived from that gap, the date shifts each year. The Netherlands is shown here as an example.
According to final figures from Statistics Netherlands (CBS) for 2025, published on 16 October 2026, women earn on average 90.2% of men's hourly pay: a gap of 9.8%. 9.8% × 365 days = 35.8 days, counted back from 31 December. The date is our own calculation, not an officially announced campaign date. It reflects the average hourly pay gap across all jobs, not pay for the same job. CBS figures ↗
How does your organisation stand?
The free Quick Scan shows in ten minutes where you need to act.