Employers with 250 or more workers fall into the Directive's largest reporting tier. Under Article 9(2), they must provide the required gender pay gap information by 7 June 2027 and every year thereafter, using data relating to the previous calendar year. The report must cover all seven Article 9 metrics, including overall and median gender pay gaps, complementary or variable pay gaps, receipt of variable pay, quartile distribution and worker-category pay gaps. Management must confirm the accuracy of the information after consulting workers' representatives, and the Article 9 data must be communicated through the national reporting framework.
Jurisdiction: European Union
The 250+ Worker Tier Has the Most Frequent Reporting Cycle
Article 9(2) places employers with 250 workers or more in the highest-frequency reporting tier. Their first report is due by 7 June 2027, and reporting is required every year thereafter. The information must relate to the previous calendar year. This means the reporting obligation is not a one-off exercise. Employers in this tier need an annual process for data extraction, pay-component classification, quality checks, worker-category mapping, management confirmation and submission. A recurring process is especially important because the same organisation may need to explain changes in the reported figures from one year to the next and maintain a defensible methodology over time.
All Seven Article 9 Metrics Must Be Included
The employer-size threshold changes the timing and frequency of reporting, not the set of core metrics. Employers with 250 or more workers must report the gender pay gap, the gender pay gap in complementary or variable components, the median gender pay gap, the median gender pay gap in complementary or variable components, the proportion of female and male workers receiving complementary or variable components, the proportion of female and male workers in each quartile pay band, and the gender pay gap by categories of workers broken down by ordinary basic wage or salary and complementary or variable components. These measures should be treated as separate reporting outputs with documented calculations and source data.
The Report Uses the Previous Calendar Year's Data
Article 9(2) states that the required information relates to the previous calendar year. For the first 7 June 2027 deadline, employers should therefore plan around the relevant 2026 reporting data, subject to any national rules that clarify operational details. This previous-year approach gives employers time to close payroll records, reconcile variable compensation and validate worker counts and categories before submission. Employers should define a reporting cut-off, identify the systems that hold each required pay component and record any adjustments made between raw payroll data and the final reporting dataset.
Management Must Confirm Accuracy After Consulting Worker Representatives
Article 9(6) requires the accuracy of the information to be confirmed by the employer's management after consulting workers' representatives. Workers' representatives must also have access to the methodologies applied by the employer. For a large employer, this creates a governance requirement around the calculations as well as a data requirement. A practical process should identify who prepares the calculations, who reviews them, how worker representatives are consulted, what methodology materials are shared and who gives the final management confirmation. The record of that process can help the employer respond to later questions about the figures or methods used.
Reporting Includes Communication to the Competent Authority
Article 9(7) requires the Article 9 information to be communicated to the authority responsible for compiling and publishing the data under the Directive's monitoring framework. Employers may also publish the information in points (a) to (f) on their own website or make it publicly available in another manner. The worker-category information in point (g) has a separate communication rule: Article 9(9) requires employers to provide it to all workers and to workers' representatives, and to provide it to the labour inspectorate and equality body upon request. National implementing law will determine the practical reporting channel and any filing format.
Employers Should Be Ready to Explain Reported Differences
Article 9(10) gives workers, workers' representatives, labour inspectorates and equality bodies the right to ask for additional clarifications and details regarding reported data, including explanations of gender pay differences. Employers must provide a substantiated reply within a reasonable time. This means annual reporting should be supported by analysis, not only calculation. Large employers should be able to identify where gaps arise, whether they are concentrated in particular categories or pay components and whether objective, gender-neutral criteria explain the differences. Where differences are not justified, the Directive requires the employer to remedy the situation within a reasonable period in close cooperation with the relevant actors.
National Implementation Can Add Operational Detail
The Directive sets the EU baseline, but employers report through national legal and administrative systems. Member States may specify filing portals, data formats, worker-count rules, enforcement procedures or other practical requirements. Employers operating in more than one Member State may therefore need more than one reporting workflow even when the underlying Article 9 metrics are similar. Compliance teams should maintain a country-level matrix showing the applicable national law, reporting authority, first filing date, filing frequency, methodology guidance, worker-representative process and evidence-retention requirements.
Frequently Asked Questions
When do employers with 250 or more workers first report?
Article 9(2) requires the first report by 7 June 2027.
How often do employers with 250+ workers report?
They report every year after the first 2027 report.
Does the 250+ tier have different metrics from smaller covered employers?
No. The seven Article 9 metrics are the same. The main difference is reporting timing and frequency.
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.