Article 9 states that the required gender pay gap information relates to the previous calendar year. Employers with 250 or more workers and employers with 150 to 249 workers first report by 7 June 2027. Employers with 100 to 149 workers first report by 7 June 2031. In each case, the information relates to the previous calendar year, while national implementing rules may add technical definitions, filing windows or data-cutoff instructions.
Jurisdiction: European Union
Article 9 Uses the Previous Calendar Year
For each mandatory reporting tier, Article 9 states that the information provided relates to the previous calendar year. The reporting deadline and the reporting period are therefore different concepts: the deadline falls later, while the data describe the immediately preceding calendar year.
The 2027 Reporting Tiers Use Prior-Year Data
Employers with 250 or more workers and employers with 150 to 249 workers first report by 7 June 2027. Their Article 9 information relates to the previous calendar year. Employers should therefore close and reconcile the relevant payroll data before calculation and review begin.
The 100-to-149 Tier Follows the Same Rule
Employers with 100 to 149 workers first report by 7 June 2031 and every three years thereafter. The same previous-calendar-year rule applies. The later start date does not create a different reporting-period concept.
A Reporting Calendar Should Work Backward From the Filing Date
A practical calendar should work backward through year-end payroll close, data extraction, pay-component mapping, worker-category assignment, metric calculation, quality review, worker-representative consultation and management confirmation. National law may specify the final filing window or portal requirements.
Frequently Asked Questions
Does the report cover the year of the filing deadline?
No. Article 9 states that the required information relates to the previous calendar year.
Does the same rule apply to 100 to 149 worker employers?
Yes. Their first report is due by 7 June 2031 and also relates to the previous calendar year.
Can national law add filing instructions?
Yes. National implementing rules may add procedural requirements such as portals, formats and technical deadlines.
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.