Deep dives

Articles on the Directive in detail.

Individual duties, deadlines and the status of national transposition – covered article by article.

Articles: 11

Basics

What the Directive regulates and by when.

Duties

What employers actually have to do.

Countries

Status of national transposition.

  • Austria

    Implementing the Pay Transparency Directive in Austria

    Status of the EU Pay Transparency Directive in Austria: current law (Equal Treatment Act, income reports), the labour ministry’s draft bill and what employers should do now.

    Updated on · 3 min read
  • Germany

    Implementing the Pay Transparency Directive in Germany

    Status of the EU Pay Transparency Directive in Germany: the current Pay Transparency Act, the expert commission’s recommendations, Federal Labour Court case law and what employers should do now.

    Updated on · 3 min read
  • Legal comparison

    Pay transparency in Austria and Germany compared

    Pay transparency law compared: the Equal Treatment Act and income report in Austria, the Pay Transparency Act (EntgTranspG) in Germany, and what the EU Directive changes in both countries.

    Updated on · 3 min read

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.

  1. 01Scope · 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.

  2. 02Transparency · 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.

  3. 03Information & 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.

  4. 04Protection · 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.

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.

Ready for transparent pay?

See how your company can implement pay transparency requirements in a structured way and document them continuously.