Live module · EU Directive 2023/970

The EU Pay Transparency Directive, kept as living evidence.

Transposition deadline 7 June 2026. Pay-gap reports phase in by employer size — but the recruitment and information duties apply far sooner. Adherely tracks what applies to you and holds the evidence to prove it.

Reviewed June 2026 · sourced to EUR-Lex 2023/970

Dates depend on national transposition. The figures below are from the EU Directive. Denmark’s implementing law was still in progress when this page was last reviewed, so exact thresholds and dates may shift. Confirm with a qualified adviser before relying on them — this is not legal advice.

Who reports, and when

Employer sizeFirst reportThen
250+ employees7 June 2027Annually
150–249 employees7 June 2027Every 3 years
100–149 employees7 June 2031Every 3 years
Under 100 employeesNo EU-mandated reportMember States may extend

Reporting size-bands are only part of it. The duties below apply to employers broadly from national transposition — regardless of headcount.

What the directive asks of an employer

Pay transparency in recruitment

Candidates get the starting pay or range before the interview, and you can’t ask about their pay history.

Right to information

Employees can request their pay level and the average levels, broken down by sex, for work of equal value — answered within two months.

Gender pay-gap reporting

In-scope employers report gender pay-gap metrics on the schedule above.

Joint pay assessment

Triggered by an unjustified gap of at least 5% in a category of workers that isn’t corrected within six months.

Gender-neutral job evaluation

Pay structures and job-classification criteria must be objective and sex-neutral.

Salary-history ban

A standing policy: no asking candidates about prior pay.

Why a register, not a one-off report

The evidence is your defence.

The directive shifts the burden of proof. In equal-pay proceedings (Art. 18(2)), where a worker establishes the facts, it falls to the employer to show there was no discrimination — and an employer without documented, gender-neutral pay criteria is on the back foot.

That makes a maintained, current register — your criteria, your evidence, your audit trail — the thing you actually produce when challenged. Adherely keeps it living and turns it into review-ready drafts.

View a sample draft →

Primary sources

We cite primary sources and date-stamp them — the same currency the product is built to maintain.

See it on your own obligations

Join the design-partner cohort and we’ll map your Pay Transparency obligations and evidence together — charter pricing, no charge during validation.

Become a design partner