Wiki · Directive (EU) 2023/970

Implement the EU Pay Transparency Directive clearly.

A public manual for employers in Germany and Austria: obligations, deadlines, information rights, pay-gap reporting, joint pay assessment, data protection and practical implementation.

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Directive in four blocks

From scope to remediation.

The Directive is broad. Implementation becomes easier when structured by scope, transparency duties, information/reporting and correction/data-protection duties.

Scope · who and what

When the Directive applies and what counts as pay

Three foundations determine whether your organization is affected and how comparisons should be structured.

Art. 2 All employers are in scope

The Directive applies to private and public employers, workers and candidates. Not every duty starts at the same employer size.

Art. 3 Pay is defined broadly

Base pay, variable components, bonuses, allowances, benefits in kind, overtime, equity and other monetary advantages must be considered.

Art. 4 Equal and equivalent work

Comparisons must be based on objective, gender-neutral criteria: skills, strain, responsibility and working conditions.

Transparency · before and during employment

Disclose recruiting pay, document criteria

Transparency starts before the employment contract and continues in traceable pay criteria.

Art. 5 Transparency in recruiting

Candidates receive starting pay or a pay range and, where relevant, collective agreement information. Questions about previous pay are prohibited.

Art. 6 Disclose pay criteria

Criteria for pay, pay levels and pay progression must be easily accessible, objective and gender-neutral.

Information & reporting · who, when, what

Information rights and reporting duties

Every worker may request information; larger employers report regularly.

Art. 7 Information right within two months

Workers can request their individual pay level and average pay levels by gender for equal or equivalent work.

Art. 9 Reporting duties by size

250+ annually from 7 June 2027, 150-249 every three years from 7 June 2027, 100-149 every three years from 7 June 2031.

Protection · correction & privacy

When gaps appear and how data is protected

The Directive requires not only transparency but also consequences for deviations and GDPR-compliant processing.

Art. 10 Joint pay assessment

A joint assessment is required when a group has at least a 5% gap, no objective justification and no correction within six months.

Art. 12 Data protection and purpose limitation

Pay data must be processed in line with GDPR. Re-identification risks must be limited and data used only for equal-pay purposes.

Practical workflow

Ten steps from legal entity to audit.

This sequence follows operational implementation: first obligation profile and job logic, then data, information requests, analysis, reporting, remediation and evidence.

1. Clarify legal entities

Capture country, worker count, headcount method, works council and reporting unit. The rule engine derives obligations, deadlines and thresholds from this.

An Austrian GmbH with 120 workers is created. The app then shows triennial reporting from 2031 and works council involvement.

2. Build job architecture

Create job families, functions and levels. Each level must be described clearly and evaluated with objective criteria.

Backend Developer L2, Senior Backend Developer L4 and Engineering Manager L5 are modeled with the same evaluation dimensions but different responsibility levels.

3. Form worker categories

Group levels of equal or equivalent work into categories. Categories are the comparison unit for information rights, analysis, reporting and remediation.

Backend L4, Frontend L4 and Data Engineer L4 are grouped as category Professional IC 4 after evaluation.

4. Complete compensation data

Import or maintain active workers, gender, FTE, contract, job level, category and current pay records.

During CSV import, base_salary, bonus, allowances, fte and job_level are mapped and stored as pay records.

5. Make criteria transparent

Document pay bands, variable components and progression criteria. Criteria must be objective, traceable and gender-neutral.

For Professional IC 4, a band from EUR 62,000 to EUR 82,000 is stored, with progression based on documented criteria.

6. Secure recruiting

Manage job postings with pay range, neutral job title, collective agreement note and documented salary-history prohibition.

A Senior Controller posting contains EUR 70,000 to 85,000 gross annual pay and the salary-history checklist.

7. Process information requests

Capture worker-related requests, monitor deadline, calculate the response, review privacy, run internal review and send the written answer.

A request from 10 March 2026 automatically receives a deadline of 10 May 2026 and uses the current comparison group.

8. Run pay-gap analysis

Calculate mean, median, base pay, variable components, recipient rates and quartiles by category. Small groups are suppressed.

A category shows a 6.2% mean gap and is marked for justification or remediation.

9. Reporting and approval

Create the reporting cycle, review metrics, document management and worker-representative approval and secure the export.

The 2026 reporting period is reviewed, approved and exported as CSV/PDF for filing, works council and submission.

10. Remediation and audit

Review 5% cases, document objective justification or measures, track deadlines and secure all decisions in the audit trail.

An unexplained gap creates a remediation case with owners, measure plan and follow-up review.

Implementation in the app

Which modules help with which duty.

Pay transparency is not a single report. The platform connects job evaluation, pay criteria, compensation data, information requests, reporting, remediation and audit trail.

App module

Dashboard and organization

Shows obligations, deadlines, setup status and open decisions per legal entity.

Identify obligations by country, size and role
Document works council and reporting unit
Plan deadlines and responsibilities

App module

Job architecture

Models job families, functions, levels, evaluation points and categories of equal or equivalent work.

Create objective comparison basis
Document Article 4/6 criteria
Build function groups for analysis and information requests

App module

HRIS import and workers

Imports workers, job assignment, pay components, FTE and effective dates from CSV/XLSX.

Review data quality
Approve mapping before import
Version pay records over time

App module

Information requests

Combines request file, response deadline, comparison basis, response data, approval and proof of sending.

Process Article 7 requests on time
Secure response snapshots
Document privacy review

App module

Analysis, reporting and remediation

Calculates pay gaps, marks 5% triggers, prepares reports and manages remediation cases.

Create Article 9 metrics
Justify or resolve Article 10 cases
Export audit-ready evidence

FAQ

Common questions on pay transparency.

The answers follow the EU baseline. National transposition laws may define additional details, procedures and penalties.

What is the EU Pay Transparency Directive 2023/970?

The Directive requires employers to provide more transparency around pay, pay criteria, information rights, pay-gap reporting and remediation measures for gender-based pay differences.

Which employers are affected?

In principle, the Directive affects private and public employers. Individual duties depend on size, country, worker representation and national transposition.

When must employers report under Article 9?

Under the EU baseline, employers with 250+ workers report annually from 7 June 2027, employers with 150-249 workers every three years from 7 June 2027, and employers with 100-149 workers every three years from 7 June 2031.

What triggers a joint pay assessment under Article 10?

It becomes relevant when a worker group has a pay gap of at least 5%, the gap is not objectively justified and it is not corrected within six months.

How does Entgelt-Transparenz.at support implementation?

The platform connects job evaluation, worker categories, compensation data, recruiting checks, information requests, pay-gap analyses, reporting, remediation and audit trail.