Employers with 100 to 149 workers enter the Directive's mandatory gender pay gap reporting regime later than larger employers. Under Article 9(4), their first report is due by 7 June 2031 and every three years thereafter, using information relating to the previous calendar year. They must report the same seven Article 9 metrics as larger covered employers. Management must confirm accuracy after consulting workers' representatives. Employers in this tier should still check national law because Member States may introduce broader or earlier requirements, and Article 11 requires support for employers with fewer than 250 workers.
Jurisdiction: European Union
The 100 to 149 Worker Tier First Reports by 7 June 2031
Article 9(4) gives employers with 100 to 149 workers a later first reporting date than larger covered employers. Their first report is due by 7 June 2031. The later deadline does not remove them from the mandatory reporting framework. It phases in the obligation so smaller covered employers have more time to prepare systems, classifications, data controls and internal governance. Employers close to the 150-worker threshold should also monitor workforce size carefully because moving into the higher tier can affect the applicable first reporting timetable under national implementation rules.
Reporting Then Repeats Every Three Years
After the first 2031 report, employers with 100 to 149 workers must report every three years. As with the 150 to 249 tier, the three-year interval changes frequency but not the substantive Article 9 data set. Employers should preserve reporting definitions, calculation methods and evidence between filing years rather than rebuilding the process each time. A stable methodology also makes it easier to compare results over time and identify whether gender pay differences are narrowing, widening or moving between worker categories or pay components.
The Full Seven Article 9 Metrics Still Apply
The Directive does not create a reduced reporting template for the 100 to 149 worker tier. Covered employers must report the overall gender pay gap, the gap in complementary or variable components, the median overall gap, the median complementary or variable gap, the proportion of women and men receiving complementary or variable components, the proportion of women and men in each quartile pay band, and the gender pay gap by categories of workers with separate reporting for ordinary basic wage or salary and complementary or variable components. The main difference from larger employers is timing, not content.
The Report Relates to the Previous Calendar Year
Article 9(4) specifies that the information relates to the previous calendar year. Employers should therefore avoid treating the three-year reporting cycle as a three-year averaging period. The relevant report should be built from the prior calendar year's data, subject to the detailed rules adopted in national law. Preparation should include a clear worker population, consistent pay-component definitions, a documented approach to variable pay, quartile calculations and defensible categories of workers. These controls are particularly important for smaller employers where a limited number of workers can materially affect percentages.
Accuracy Confirmation and Worker-Representative Consultation Apply in This Tier Too
Article 9(6) applies across the reporting regime. The employer's management must confirm the accuracy of the information after consulting workers' representatives, and workers' representatives must have access to the methodologies applied. Employers with 100 to 149 workers should define this review process before the first deadline rather than leaving it until the report is complete. Clear documentation can include calculation rules, data sources, category-of-worker methodology, exclusions or adjustments, review comments and the final management confirmation.
Member States Must Support Employers With Fewer Than 250 Workers
Article 11 requires Member States to provide technical assistance and training to employers with fewer than 250 workers and to the workers' representatives concerned to facilitate compliance with the Directive. This provision is particularly relevant to employers in the 100 to 149 tier because they may have smaller HR, compensation or legal teams than large employers. The precise form of support will depend on national implementation, so employers should monitor guidance from labour ministries, equality bodies, labour inspectorates and other competent national authorities as the 2031 reporting date approaches.
National Law May Bring Smaller Employers Into Reporting Earlier or More Broadly
The Directive sets minimum EU rules and expressly allows Member States to go further. Article 9(5) permits national law to require reporting from employers with fewer than 100 workers, which shows that national systems may have broader coverage than the Directive baseline. Employers in the 100 to 149 tier should therefore not assume that 2031 is automatically the only relevant date in every country. National transposition should be checked for earlier deadlines, different workforce-count rules, filing portals, formats, publication duties and enforcement provisions.
Frequently Asked Questions
When do employers with 100 to 149 workers first report?
Article 9(4) sets the first deadline at 7 June 2031.
How often do employers with 100 to 149 workers report?
They report every three years after the first 2031 report.
Do employers with 100 to 149 workers report the same metrics as larger employers?
Yes. The same seven Article 9 measures apply.
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.