Reporting
Reporting duties under Article 9: who must report what, and when
Article 9 of the EU Pay Transparency Directive requires employers with 100 or more workers to report regularly on the gender pay gap – for the first time by 7 June 2027 (250+ and 150–249 workers) or by 7 June 2031 (100–149 workers). The metrics are submitted to a national monitoring body and are partly published.
Thresholds and frequency
The reporting duty is tiered by employer size:
- 250+ workers: annually, first report by 7 June 2027.
- 150–249 workers: every three years, first report by 7 June 2027.
- 100–149 workers: every three years, first report by 7 June 2031.
- Below 100 workers: voluntary; Member States may extend the duty nationally.
Which metrics must be reported
The report covers, among other things: the overall gender pay gap, the gap in complementary or variable components, median values, the proportion of female and male workers receiving variable components, the distribution across quartile pay bands, and the gap per category of workers, broken down by basic salary and variable components.
The per-category metric is the most demanding: it requires defensible categories of equal work and work of equal value – and this metric is not submitted to the authority but provided to all workers and their representatives.
Accuracy, confirmation and participation
Management must confirm the accuracy of the information, and worker representatives must be involved and can challenge methodology and figures. The monitoring body publishes company-level metrics; workers and their representatives can request clarifications and additional breakdowns. A report based on undocumented methodology quickly becomes a liability.
Relationship to the Austrian income report
The existing Austrian income report under Section 11a of the Equal Treatment Act (every two years, from 150 workers, internal only) remains in force until national transposition, but does not cover the Directive: it lacks external submission, quartile distribution, per-category metrics and the 5% mechanism. How the legislator will merge both instruments is an open transposition question (as of July 2026).
Frequently asked questions
From how many workers does reporting apply?
From 100 workers. Employers with 250+ report annually from 2027, 150–249 every three years from 2027, and 100–149 every three years from 2031.
Are the reported metrics published?
Yes, the central company-level metrics are made accessible by the monitoring body. The per-category metrics go to workers and their representatives.
Does the EU report replace the Austrian income report?
That is still open. Until Austrian transposition, both regimes exist: Section 11a GlBG unchanged, and the Directive metrics as the upcoming standard.