Employers with 150 to 249 workers must first provide the Article 9 gender pay gap information by 7 June 2027 and then every three years thereafter. The information relates to the previous calendar year. They must report the same seven core metrics as employers with 250 or more workers. The difference is frequency: the 150 to 249 tier reports every three years rather than annually. Management must confirm the accuracy of the information after consulting workers' representatives, and employers must follow the relevant national implementation rules for submission and publication.
Jurisdiction: European Union
The First Reporting Deadline Is 7 June 2027
Article 9(3) requires employers with 150 to 249 workers to provide the required pay gap information by 7 June 2027. This is the same first deadline that applies to employers with 250 or more workers. The difference appears after the first report, not at the start of the regime. Employers in this tier should therefore prepare on the same initial timeline as larger employers, including data mapping, worker-category methodology, calculation controls, worker-representative consultation and management confirmation. Waiting until after larger employers have completed their first cycle would miss the Directive's timetable.
Reporting Repeats Every Three Years
After the first report, Article 9(3) requires employers with 150 to 249 workers to report every three years. The less frequent cycle reduces filing frequency compared with the 250+ tier, but it does not reduce the content of the report. Employers should maintain the underlying data definitions and methodology between reporting years so the next report can be produced consistently and explained against the previous one. A documented reporting playbook can help preserve continuity when HR systems, compensation structures, payroll providers or responsible staff change during the three-year interval.
The Same Seven Article 9 Metrics Apply
Employers in the 150 to 249 worker tier must report all seven measures listed in Article 9(1). These cover the overall gender pay gap, the gap in complementary or variable components, the median overall gap, the median variable-component gap, the proportion of women and men receiving complementary or variable components, gender distribution across quartile pay bands, and gender pay gaps by categories of workers with separate treatment of ordinary basic wage or salary and complementary or variable components. The Directive does not provide a reduced metric set for this employer-size band.
The Reporting Period Is the Previous Calendar Year
Article 9(3) states that the information relates to the previous calendar year. Employers should therefore establish a repeatable method for identifying the relevant worker population and pay data for each reporting cycle. The three-year filing rhythm should not be confused with a three-year measurement period. The report is tied to the previous calendar year's information, not an average of the entire three-year interval. National implementation may provide operational detail on worker-count dates, data submission formats or calculation conventions, so those rules should be incorporated into the employer's reporting calendar.
Management Confirmation and Worker-Representative Consultation Still Apply
The governance provisions in Article 9 apply regardless of whether the employer reports annually or every three years. Article 9(6) requires management to confirm the accuracy of the information after consulting workers' representatives, and workers' representatives must have access to the methodologies applied. Employers should therefore preserve calculation notes, definitions, source-data documentation and methodology decisions even in non-reporting years. This makes it easier to explain the next report, respond to questions and show how any methodology changes affect comparability with the prior cycle.
Three-Year Reporting Does Not Remove the Need to Address Unjustified Gaps
A longer reporting interval does not mean employers can ignore issues between filing dates. Article 9(10) allows workers, worker representatives, labour inspectorates and equality bodies to seek clarifications about reported data, and unjustified gender pay differences must be remedied within a reasonable period. Article 10 can also trigger a joint pay assessment where its conditions are met. Employers should therefore use the reporting results as a management and equal-pay diagnostic rather than treating the three-year filing cycle as the only moment when pay structures are reviewed.
National Rules May Affect the Practical Reporting Process
The Directive establishes the core EU obligation, but Member States implement it through national law. Employers should confirm which national authority receives the data, whether a specific reporting template or portal applies, how workforce size is determined and whether the Member State has adopted more favourable or broader requirements. Multi-country employers may need different local filing procedures even though Article 9 supplies a common EU framework. A country-by-country reporting calendar can help keep those differences visible.
Frequently Asked Questions
When do employers with 150 to 249 workers first report?
Their first Article 9 report is due by 7 June 2027.
How often do employers with 150 to 249 workers report?
They report every three years after the first 2027 report.
Do they report fewer metrics than employers with 250+ workers?
No. The same seven Article 9 reporting 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.