Reporting frequency under the EU Pay Transparency Directive depends on workforce size. Employers with 250 or more workers must first report by 7 June 2027 and then every year. Employers with 150 to 249 workers must first report by 7 June 2027 and then every three years. Employers with 100 to 149 workers must first report by 7 June 2031 and then every three years. In each case, the information relates to the previous calendar year. National implementing law may add procedural requirements or impose broader obligations.
Jurisdiction: European Union
Reporting Frequency Depends on Employer Size
Article 9 does not apply one reporting cycle to every covered employer. The Directive uses employer size to determine how frequently gender pay gap information must be provided. Employers with 250 or more workers are placed on an annual reporting cycle because they are the largest organisations covered by the framework. Employers with 150 to 249 workers and employers with 100 to 149 workers report every three years after their first applicable deadline. This staged approach means compliance calendars should be built around workforce size rather than assuming one universal reporting timetable.
Employers With 250 or More Workers Report Every Year
Under Article 9(2), employers with at least 250 workers must provide the required information by 7 June 2027 and every year thereafter. The annual cycle makes reporting a recurring operational process rather than an occasional exercise. Employers in this tier should maintain stable data definitions, pay-component mappings, worker-category rules and quality controls so each reporting year can be reproduced consistently. Because the report concerns the previous calendar year, organisations should close and validate the relevant data soon after year-end rather than waiting until the June deadline to begin preparation.
Employers With 150 to 249 Workers Report Every Three Years
Article 9(3) requires employers with 150 to 249 workers to provide their first report by 7 June 2027 and every three years thereafter. Their first reporting date therefore matches the 250+ tier, but their ongoing cadence is less frequent. This does not remove the need for a repeatable reporting process. Data ownership, calculation logic and documentation should still be retained between reporting years so the organisation can reconstruct its methodology and avoid rebuilding the reporting framework from scratch every three years.
Employers With 100 to 149 Workers Report Every Three Years From 2031
Article 9(4) gives the 100 to 149 worker tier a later first deadline. These employers must provide the required information by 7 June 2031 and every three years thereafter. The later start date creates more preparation time, but employers near or above the threshold should still plan early because the same seven Article 9 metrics must ultimately be produced. Organisations whose workforce size is changing should monitor whether they move into another reporting tier under national implementing rules and should not assume their current cadence will remain unchanged indefinitely.
Each Report Relates to the Previous Calendar Year
The reporting frequency should be distinguished from the reporting period. Article 9 states that the required information relates to the previous calendar year. A report submitted by the relevant June deadline therefore looks back to the prior year rather than reporting a current-year snapshot. This matters for payroll extraction, employee population rules, variable-pay data and year-end reconciliations. Employers should define which records form the final reporting population and document how corrections, late payroll adjustments or post-year-end changes are handled under the applicable national methodology.
National Law May Add More Detailed Calendar Requirements
Directive (EU) 2023/970 requires national implementation, so Article 9 provides the EU baseline rather than the complete filing procedure for every country. Member States may specify submission portals, data formats, responsible authorities, workforce-count rules and additional obligations. They may also impose more favourable protections for workers. Employers should therefore maintain an EU-level reporting calendar and a country-specific implementation layer. This is particularly important for groups operating in several Member States, because the same Article 9 reporting principle may be implemented through different administrative processes.
Frequently Asked Questions
Do all covered employers report every year?
No. Only employers with 250 or more workers report annually under the Directive baseline. Employers with 150 to 249 and 100 to 149 workers report every three years after their first applicable deadline.
When does the three-year cycle start?
For employers with 150 to 249 workers, the first report is due by 7 June 2027. For employers with 100 to 149 workers, the first report is due by 7 June 2031.
What period does each report cover?
Article 9 states that the required information relates to the previous calendar year.
Related Guides
Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.