At 150 workers, an employer enters the Article 9 reporting band for employers with 150 to 249 workers. Under Directive (EU) 2023/970, that band must first provide the required gender pay gap information by 7 June 2027 and then every three years, using information relating to the previous calendar year. The main significance of the threshold is the earlier reporting timetable compared with employers in the 100 to 149 worker band. Other pay-transparency and equal-pay duties do not begin only at 150 workers, and employers should confirm under national implementation how the applicable workforce count and reporting process are determined.
Jurisdiction: European Union
The 150-Worker Threshold Moves the Employer Into the 2027 Reporting Group
The most important change at 150 workers is the reporting timetable. Article 9 places employers with 150 to 249 workers in the group that must first provide the Directive's gender pay gap information by 7 June 2027. This is earlier than the first Directive-level reporting date for employers with 100 to 149 workers, which is 7 June 2031. The threshold therefore matters most as a planning boundary for Article 9 reporting. An employer that is close to 150 workers should not assume that it can prepare on the same timetable as an employer that remains in the lower reporting band.
The Reporting Cycle Is Every Three Years
Employers in the 150 to 249 worker band report by 7 June 2027 and every three years thereafter. The information relates to the previous calendar year. Article 9 requires more than a single headline percentage. The reporting set includes the gender pay gap, median gap, gaps in complementary or variable components, the proportion of female and male workers receiving those components, representation in each pay quartile and pay gaps by categories of workers. Employers therefore need a repeatable reporting process that can be refreshed on the three-year cycle rather than a one-off calculation assembled only for the first deadline.
Reaching 150 Workers Does Not Activate the Rest of the Directive for the First Time
The 150-worker line should not be described as the point when pay transparency begins. Applicant pay-information rules, restrictions on salary-history questions, worker information rights, pay-setting transparency and the equal-pay framework are separate from the Article 9 reporting timetable. An employer growing from 140 to 150 workers should already have processes for those areas. Crossing 150 changes the reporting band and brings forward the Directive-level reporting timetable, but it does not convert an otherwise exempt employer into a covered employer for the first time. Scope and reporting thresholds should remain separate entries in the compliance map.
The Employer Needs Article 9 Data Before the Deadline Arrives
Employers approaching 150 workers should review whether payroll, HR and compensation systems can produce the Article 9 data consistently. The reporting metrics depend on ordinary basic wage or salary, complementary or variable components, pay quartiles and categories of workers. The category-of-worker concept is especially important because the Directive links it to workers performing the same work or work of equal value. If the employer's job architecture is inconsistent, reporting can expose classification problems that are difficult to solve at the last minute. A readiness exercise should therefore test data ownership, field definitions, job categories, quality controls and the process for explaining objective gender-neutral pay differences.
Management Must Confirm Accuracy After Consulting Workers' Representatives
Article 9 does not treat reporting as a purely technical export from payroll. The accuracy of the information must be confirmed by the employer's management after consulting workers' representatives. Workers' representatives must also have access to the methodologies applied by the employer. That makes governance part of reporting readiness. Employers should document who produces the figures, who reviews them, which methodology is used, when representatives are consulted and who provides final management confirmation. A clear assurance process is particularly useful when the organisation has recently crossed a threshold and its reporting procedures are still being formalised.
Employers Below 250 Workers Remain Within Article 11's Support Group
An employer with 150 to 249 workers also falls within Article 11, which requires Member States to provide technical assistance and training to employers with fewer than 250 workers and to the workers' representatives concerned. This does not remove the employer's obligations, but it is relevant when planning implementation. National authorities may provide guidance, tools or training that can help smaller reporting employers build their processes. Employers should check the support available in the Member State alongside the binding national implementing rules rather than assuming that every jurisdiction will deliver assistance in the same format or through the same authority.
Confirm How the 150-Worker Boundary Is Applied Nationally
The Directive states the reporting bands but does not provide a complete operational headcount formula in Article 9 for every workforce scenario. Employers should therefore confirm how the applicable national implementation determines whether the employer falls into the 150 to 249 band. Questions may arise when headcount changes during the year, legal entities are reorganised, employees move between group companies or non-standard worker arrangements are present. The scope record should identify the relevant employer, the counting date or period used under national rules, the worker categories included and the evidence supporting the conclusion. This is safer than importing a headcount method from an unrelated tax, accounting or SME regime.
Frequently Asked Questions
When do employers with 150 to 249 workers first report?
Under Article 9, employers with 150 to 249 workers must first provide the required information by 7 June 2027, relating to the previous calendar year.
How often do employers with 150 to 249 workers report?
They report every three years after the first Directive-level report due by 7 June 2027.
Does crossing 150 workers make every pay-transparency duty start?
No. The 150-worker threshold mainly changes the Article 9 reporting timetable. Other applicant, worker and equal-pay obligations can apply independently of that threshold.
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Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.