Checklist

EU Pay Transparency Directive Readiness Checklist

Global HR

Legal & compliance

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The EU Pay Transparency Directive is designed to close the gender pay gap across the European Union. It introduces three core obligations: requiring employers to disclose salary ranges before and during hiring, giving workers the right to access and compare pay information, and mandating regular gender pay gap reporting tied to headcount.

Underlying all three is a requirement to ground pay decisions in objective, gender-neutral criteria—and to demonstrate that when asked. This checklist gives you a clear, actionable path to compliance, organized by company size.

Built for HR, legal, and people ops teams

This template is designed for any organization with employees in EU member states, with three different practical checklists depending on your headcount. Your organization’s size will dictate your obligations under the Directive, and which deadlines to pay attention to:

50–150 employees: Establish your foundations—job architecture, pay bands, and hiring disclosure requirements.

150–250 employees: Strengthen documentation, expand manager training, and prepare for your first reporting cycles.

250+ employees: Implement rigorous process controls and stricter audit trails across all pay decisions.

How to use this template

Step 1: Select the relevant checklist for your organization. Your headcount will dictate your immediate next steps, making the version for your current size the right starting point. If you’re growing toward the next threshold, glancing at the next tier will help you plan for the future.

Step 2: Assess your readiness at a glance. Start with the "Your readiness checklist at a glance" section to quickly identify where your organization stands and spot compliance gaps.

Step 3: Follow the "How to complete each step" guide. When you're ready to act—or when a checklist item needs more context—use the detailed guidance section to move forward with confidence.

Step 4: Build in recommended order. Each checklist has a recommended build sequence. Follow it where possible. Foundational steps like job architecture and compensation bands unlock everything that comes after.

FAQs

When does the Directive apply and who must comply?

EU Directive 2023/970 applies to employers across all EU member states. It enters into force in stages based on headcount, with the largest employers (250+) subject to reporting obligations first. Specific deadlines depend on how your member state has transposed the Directive into national law.

What are the three core obligations under the Directive?

Employers must: disclose salary ranges in job postings and during hiring; give workers the right to request and access pay information for comparable roles; and report on gender pay gaps at defined intervals based on company size. All pay decisions must be grounded in objective, gender-neutral criteria.

How does the checklist account for different company sizes?

The template is organized into three headcount bands—50–150, 150–250, and 250+—reflecting the Directive's reporting thresholds. Each band has its own checklist with a recommended build order. If your organization is growing toward the next threshold, the template encourages you to scan ahead so you can prepare early.

Does the checklist cover all EU member states?

This checklist reflects Directive minimums. National transposition timelines and requirements vary by member state, and some may diverge from the dates included here. Your actual obligations depend on where your employees are located, the sector you operate in, and how your member states choose to implement. Always consult qualified legal counsel for jurisdiction-specific guidance.

What foundational work do we need before using this checklist?

Job architecture and compensation band structures are foundational—completing later steps correctly depends on having these in place. The checklist's recommended build order reflects these dependencies. If you haven't started yet, begin there before moving on to disclosure requirements and reporting workflows.

Can we use this checklist if we're not yet at 50 employees?

Yes. Building compliant pay structures early reduces the cost of catching up later. The 50–150 band is a practical starting point, and many of the foundational steps—particularly job architecture and pay band design—benefit from being set up before you hit reporting thresholds.