7 June 2027 is the first major reporting deadline under Article 9 of the EU Pay Transparency Directive. Employers with 250 workers or more must provide the required gender pay gap information by that date and every year thereafter. Employers with 150 to 249 workers must also report by 7 June 2027, but then report every three years. The information relates to the previous calendar year, so employers should have the necessary job, worker-category and compensation data prepared well before the deadline.
Jurisdiction: European Union
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Which Employers Report by 7 June 2027?
Article 9 divides reporting frequency according to employer size. Employers with 250 workers or more must provide the required information by 7 June 2027 and then every year. Employers with 150 to 249 workers have the same first reporting date but move to a three-year reporting cycle after that. The threshold therefore affects frequency as well as timing. Employers should verify how worker numbers are determined under the applicable national implementation rather than assuming that a familiar headcount method from another reporting regime automatically applies.
The First Report Relates to the Previous Calendar Year
The Directive states that the Article 9 information relates to the previous calendar year. For the first 7 June 2027 reporting point, employers therefore need to be able to produce the relevant information for the preceding calendar year. This makes data readiness a 2026 issue, not merely a June 2027 filing task. Compensation teams need consistent records for basic salary, complementary or variable compensation, worker categories and the demographic information needed to calculate the prescribed metrics.
What Information Article 9 Requires
Article 9 requires more than one headline gender pay gap figure. The reporting set covers the overall gender pay gap, the gap in complementary or variable components, the median gender pay gap, the median gap for complementary or variable components, the proportion of female and male workers receiving those components, the gender distribution within each quartile pay band, and gender pay gaps by categories of workers. Category-level analysis is particularly important because an organisation-wide average can hide differences within comparable groups.
Why Worker Categories Need to Be Ready Before Reporting
The Directive's reporting framework connects directly with the concept of categories of workers doing the same work or work of equal value. An employer cannot produce meaningful category-level reporting if roles have not been grouped using a defensible methodology. That is why job architecture and gender-neutral job evaluation are not separate theoretical exercises. They influence the structure of the data used for pay analysis. Employers should test category assignments before the reporting cycle so disputes over classification do not emerge only when the figures are being finalised.
Management and Worker Representatives Have Roles in the Process
The Directive provides that the accuracy of the reported information is confirmed by the employer's management after consultation with workers' representatives. Worker representatives are also entitled to access the methodologies applied by the employer. Reporting should therefore have a governance process rather than being treated as a spreadsheet produced by one analyst. Employers need clear ownership for source data, calculations, methodology, review, management confirmation and communication with representatives so that the published figures can be explained and reproduced.
What Employers Should Do Before 7 June 2027
Preparation should begin with the data model. Employers should identify covered entities, determine the relevant worker population, map compensation components, review worker categories and test the seven Article 9 metrics. They should also identify the national reporting authority or mechanism created by implementing legislation. A dry run is valuable because it exposes missing data, inconsistent job classifications and unexplained differences while there is still time to investigate them. Reporting should be the output of a functioning pay-transparency system rather than the first time the organisation examines its data.
Frequently Asked Questions
Do employers with 250 or more workers report every year?
Yes. Under Article 9, employers with 250 workers or more report by 7 June 2027 and every year thereafter.
Do employers with 150 to 249 workers also report in 2027?
Yes. Their first Directive-level reporting date is also 7 June 2027, but after that they report every three years rather than annually.
Do employers with 100 to 149 workers report in 2027?
Their Directive-level reporting timetable starts later, with the first reporting date set for 7 June 2031. National law can still create additional requirements that should be checked separately.
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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.