EU Pay Directive Checklist

What is the EU Pay Directive?

The EU pay directive aims to enforce equal pay for equal work or work of equal value for all men and women within EU member states. This applies to part-time workers, workers on a fixed-term contacts, and those with a permanent employment contract, including employees at management level. On 7 June, 2026 the directive will come into effect, meaning that companies have a few more months to prepare and ensure their pay policies are compliant with the general guidelines to start. 

What is included in the EU Pay Directive Checklist? 

The Robert Walters EU Pay Checklist includes details on the organisation, hiring process, pay structures, role and job functions, and more. 

Our team have also included key takeaways and best practices that every organisation should consider when reviewing the directive readiness and ability to effectively report on compliance. 

Which companies need to comply with the EU Pay Directive? 

Employers will have varying obligations depending on the size of the organisation. However, all employers within the EU and companies that have EU offices will need to comply with the directive. Larger companies with more than 250 employees will be required, as early as June 2027, to communicate their gender pay gap reports each year to the authority in charge of publishing the data.

Depending on the company size, the reporting requirement will come into effect between June 2027 and June 2031 on an annual or triennial basis. Although companies with less than 100 employees are not required to report based on general guidelines as yet, EU member states could incorporate compulsory reporting for an organisation of any size if written into national law. 

When should organisations act on EU Pay Directive readiness?

To ensure compliance, there are a few key things organisations should take into account when deciding to act on their compliance readiness and reviewing their current pay structures. 

When to act: 

1. You do not know if your current salaries align with the market
2. Pay relies on “market judgement” without structure
3. Hiring managers negotiate freely
4. Job evaluation has never been done
5. Historic pay gaps remain unresolved

What are the employee rights regarding the EU pay directive?

Employers will have an obligation to give candidates clear information about the salary range for the role. Currently, the directive states that the informations needs to provided in a way that ensures an informed and transparent negotiation on pay. In addition, employees can request information on their individual pay and the average pay levels across the organisation for workers performing the same work as them or work of equal value to theirs. Additionally, pay secercy clauses are not permitted meaning that employment contact terms that prohibit workers from disclosing information about their pay will not be allowed.