Transposition status
Checked on 15 September 2026- AustriaDraft under coordination
On 6 June 2026, the labour ministry submitted a draft bill for coordination within the government; a government bill has not yet been tabled. According to media reports, it provides for income reports from 100 workers and administrative fines of up to EUR 60,000 for repeated breaches.
Sources: ORF, 7 June 2026 · ORF, 6 August 2026
- GermanyDraft bill pending
According to the federal government, preparatory work was completed in July 2026, but no draft bill has been published yet. Media reports point to a law in 2027. Until then, the 2017 Pay Transparency Act applies.
Sources: Bundestag, 16 July 2026 · Bundestag, 9 September 2026 · taz, 1 June 2026 · EntgTranspG
- Other EU countriesFirst laws in force
Italy, Slovakia and Malta, among others, transposed on time; Greece followed in July 2026. Parliaments in the Netherlands and Finland are debating bills. The European Commission rejects postponing the deadline.
Sources: Slovakia · Italy · Malta · Greece · Netherlands · Finland · European Commission
The key dates
The Directive’s timeline at a glance:
- 6 June 2023: Directive (EU) 2023/970 enters into force.
- 7 June 2026: transposition deadline for Member States. From transposition, recruiting transparency, disclosure of pay criteria and the information right apply.
- 7 June 2027: first pay gap report for employers with 250+ workers (annually thereafter) and for employers with 150–249 workers (every three years thereafter).
- 7 June 2031: first pay gap report for employers with 100–149 workers (every three years thereafter).
Why the 2027 report needs 2026 data
The report due by 7 June 2027 covers a past reference year – typically calendar year 2026. The data foundation for the first report is therefore being created now: worker categories, complete compensation data including variable components and a defensible job evaluation must exist before the reference period, not after it.
Realistically, employers need six to twelve months of lead time for job architecture, category building, data cleansing and a first internal dry run of the pay gap calculation – including time to justify or correct identified gaps before the cut-off date.
Duties without thresholds already apply
Independently of the reporting cycle, the individual transparency duties apply to all employers from national transposition: pay ranges in recruiting, the ban on salary history questions, accessible pay criteria and the information right with its two-month response deadline. Since the transposition deadline has passed, these processes should be in place now – even where the national act is still pending.
Recommended roadmap
A proven roadmap working backwards from the first reporting date:
- Immediately: clarify the obligation profile per legal entity (country, headcount, threshold, worker representation).
- Quarter 1: build job architecture and objective evaluation criteria, form worker categories.
- Quarter 2: complete compensation data, adapt recruiting processes and the information-request workflow.
- Quarter 3: run a first pay gap analysis, justify 5% cases or start remediation.
- Quarter 4: test the reporting process with approvals, worker representatives and export.
Frequently asked questions
When is the first pay gap report due?
Employers with 250+ and with 150–249 workers report for the first time by 7 June 2027; employers with 100–149 workers report for the first time by 7 June 2031.
Which duties apply before the first report?
From national transposition, all employers must provide recruiting transparency (pay range, no salary history questions), disclose pay criteria and answer workers’ information requests.
What happens if a Member State misses the deadline?
The transposition obligation remains; the Commission can start infringement proceedings. Employers are well advised to implement the EU baseline already, as national laws may define retroactive reference periods.
Sources
Not legal advice. The content is based on Directive (EU) 2023/970 as of the update date shown; specific obligations follow from national transposition.