Frequently asked questions
What is the transposition deadline, and does it matter that my country missed it?
Member states had to bring the rules into force by 7 June 2026 (Article 34). Most missed it. It does not get you off the hook: the reporting deadlines run from the Directive itself, so your first-report obligation stands. Late states face possible Commission infringement proceedings, and many are targeting 1 January 2027.
My company has 180 employees in one country. When is my first report due?
You are in the 150 to 249 band. Your first gender pay gap report is due by 7 June 2027 on 2026 pay data, then every three years.
Do the 100 to 149 employee rules really not start until 2031?
Yes. The 100 to 149 band files its first report by 7 June 2031 on 2030 pay data, then every three years. The pre-employment rules and the right to information still apply from national transposition, whatever your size.
Is the first report based on 2026 pay data?
For the 250+ and 150 to 249 bands, yes: the first report is due by 7 June 2027 relating to the previous calendar year, which is 2026. The 100 to 149 band reports on 2030 data.
What counts as an employee for the headcount test?
The Article 9 test is based on the number of workers the employer has. Exactly how workers are counted, including part-time and fixed-term staff, is set out in the Directive and clarified in national transposition, which is one of the things your report flags for your member state.
What is a joint pay assessment and when am I forced to do one?
Under Article 10, if pay reporting shows an average gap of at least 5% in any worker category that you have not justified on objective, gender-neutral grounds and have not remedied within six months, you must carry out a joint pay assessment with worker representatives to identify, analyse and remedy the difference.
Can I still ask candidates what they earn now?
No. Article 5 bans asking applicants about their pay history in current or previous employment, and gives applicants the right to information on the initial pay or pay range before the interview.
Do I have to put salary ranges in job adverts?
Applicants have the right to the initial pay or pay range before the interview, and vacancy notices and job titles must be gender-neutral. Whether the range must sit in the advert itself, rather than be provided on request, depends on how your member state transposes Article 5. Your report notes your country's position.
My country has not transposed yet. Am I off the hook until it does?
No. The reporting phase-in dates come from the Directive, so they apply on the same timeline. Where your state has an existing regime (for example Ireland at 50+ or Spain's Royal Decree 902/2020), other duties may already apply. Your report sets out what binds you now versus at transposition.
Does this report replace a pay audit or legal advice?
No. It is a scoping and planning brief: your in-scope verdict, deadlines, disclosure duties and your country's status, dated and sourced. A full pay audit and legal sign-off are separate exercises, and the report is built to help you commission them well.