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.
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.
- Fundamentals
The EU Pay Transparency Directive (EU) 2023/970 at a glance
What the EU Pay Transparency Directive (EU) 2023/970 regulates: scope, definition of pay, transparency duties, information rights, reporting obligations and penalties.
- Deadlines
Deadlines and timeline of the Pay Transparency Directive
All deadlines of the EU Pay Transparency Directive: transposition by 7 June 2026, first pay gap reports in 2027, tiered thresholds by employer size until 2031.
- Penalties
Penalties, compensation and burden of proof under the Pay Transparency Directive
The consequences of breaching the EU Pay Transparency Directive: compensation without an upper limit (Art. 16), burden of proof on the employer (Art. 18), limitation periods of at least three years (Art. 21), fines (Art. 23) and public procurement (Art. 24).
Duties
What employers actually have to do.
- Equal value
Work of equal value and job evaluation under Articles 4 and 6
What work of equal value means under the EU Pay Transparency Directive, which criteria Article 4 sets, what Article 6 requires on disclosing pay criteria and how to build a defensible job evaluation.
- Recruiting
Pay transparency in recruiting: Article 5 duties
Article 5 of the Pay Transparency Directive in recruiting: disclose the pay range in advance, salary history ban, gender-neutral postings – and current Austrian practice.
- Information right
The Article 7 information right: process, deadlines, practice
The information right under Article 7 of the Pay Transparency Directive: who can ask, what must be answered, the two-month deadline and how employers set up the process.
- Reporting
Reporting duties under Article 9: who must report what, and when
Reporting duties of the Pay Transparency Directive: thresholds from 100 workers, metrics, 2027/2031 deadlines, and the role of worker representatives.
- Remediation
Joint pay assessment under Article 10: the 5% trigger
When Article 10 of the Pay Transparency Directive triggers a joint pay assessment: 5% gap, objective justification, six-month deadline and the process with worker representatives.
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.
- 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.
- 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.
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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.
- 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. 2All 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. 3Pay is defined broadly
Base pay, variable components, bonuses, allowances, benefits in kind, overtime, equity and other monetary advantages must be considered.
- Art. 4Equal and equivalent work
Comparisons must be based on objective, gender-neutral criteria: skills, strain, responsibility and working conditions.
- Art. 2
- 02Transparency · before and during employment
Disclose recruiting pay, document criteria
Transparency starts before the employment contract and continues in traceable pay criteria.
- Art. 5Transparency in recruiting
Candidates receive starting pay or a pay range and, where relevant, collective agreement information. Questions about previous pay are prohibited.
- Art. 6Disclose pay criteria
Criteria for pay, pay levels and pay progression must be easily accessible, objective and gender-neutral.
- Art. 5
- 03Information & reporting · who, when, what
Information rights and reporting duties
Every worker may request information; larger employers report regularly.
- Art. 7Information right within two months
Workers can request their individual pay level and average pay levels by gender for equal or equivalent work.
- Art. 9Reporting 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.
- Art. 7
- 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. 10Joint 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. 12Data 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.
- Art. 10
Which of these does the software handle?See the duty checklist →
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.
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