EU Directive 2023/970 on pay transparency enters into force across all EU Member States on 7 June 2026. The basic obligations apply to all companies regardless of size: salary in job adverts, prohibition on asking about salary history and employee information rights. Pay gap reporting obligations apply from 100 employees, with a phased calendar.

What the directive requires

A) Recruitment transparency

Applies to all companies. You must indicate the starting salary or salary range in job adverts before the interview. You cannot ask candidates about their current or previous salary. Job titles and adverts must be gender-neutral.

B) Employee information rights

Criteria for determining pay, salary levels and progression must be accessible to all employees. Each employee can request, in writing, their individual pay level and average pay levels disaggregated by sex for equal or equivalent work. The company has 2 months to respond. Pay secrecy clauses are prohibited.

C) Pay gap reporting

• 250+ employees: first report by 7 June 2027, then annually.
• 150-249 employees: first report by 7 June 2027, then every 3 years.
• 100-149 employees: first report by 7 June 2031, then every 3 years.
• Under 100 employees: voluntary reporting.

Action plan for companies

Phase 1 (by 7 June 2026): audit job grades, define objective pay criteria, run an internal pay gap analysis, update job advert templates to include salary ranges, eliminate pay secrecy clauses.

Phase 2 (June 2026-June 2027): create a formal process for responding to employee information requests; build a granular pay data collection system.

This article is for informational purposes only and does not constitute legal advice.