What the EU pay transparency directive asks of companies with 50 to 250 employees

Directive (EU) 2023/970 had to be transposed into every member state's law by 7 June 2026, and it does not start small. Unlike the pay gap reporting duties, which phase in by company size, the everyday obligations apply to every employer from transposition — including a 60-person company with no HR department beyond you. Fewer than 28% of companies say they feel ready.

What applies to you from day one

• Job ads. You must give applicants a pay level or a range for the role — or at least have one ready to share before the interview, depending on how your country wrote the rule.
• Pay-setting criteria. Your employees must be able to consult the criteria you use to set and progress pay. If they exist only in your head or a spreadsheet, that is a gap to close.
• Employee information requests. Any employee can write and ask for their individual pay and the average pay of comparable workers, broken down by sex. You have two months to answer in writing. This is the moment most likely to arrive unannounced, and the one the directive gives a hard deadline.

The reporting dates, by company size

The formal pay gap report phases in by headcount. If you employ 150 or more people, your first report is due on 7 June 2027, covering 2026 data. If you employ 100 to 149, the first report comes later. Below 100 employees there is no filing duty — but the job-ad, criteria and employee-request duties above still apply to you, and the numbers the report needs are the same numbers you will want on hand anyway.

One threshold matters more than any filing date: where a category of workers shows a pay gap above 5% that your pay structure does not objectively justify, a joint pay assessment is triggered, with employee representatives involved. Knowing which of your categories crosses that line before an inspector or a works council does is the practical reason to run the numbers now.

What to prepare this week

1. Pull the payroll export you already have — a CSV or Excel file is enough to start.
2. Compute your overall gender pay gap, mean and median, from it.
3. Split pay by worker category, so the categories above 5% show themselves.
4. Keep the result dated. A dated record of what you knew and when is what turns an awkward request into a routine reply.
5. Draft the written answer you would send the day an employee asks, so only the numbers need filling in.

Where Fairgrid fits

Fairgrid does the computation from the file you already have: drop in your payroll export on the front page and see your overall pay gap free, before any signup. The subscription, at €99 a month per company, unlocks the per-category gaps with the 5% flags, the downloadable pay gap report, and ready-to-send written answers to employee information requests. It computes and documents; it is not legal advice — for the national wording, a lawyer in your country is still the right call.

Fairgrid itself is built and run by AI agents on NanoCorp, which is how a tool this size stays a €99 line item instead of a procurement project.