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EU Pay Transparency Directive compliance: four ways to prepare

Law firm, spreadsheet, HR software or a readiness review: what each does well and where it stops. Editorial comparison. Not legal advice.

Short answer: match the tool to the question

Use counsel for legal questions, a spreadsheet or HR system for pay data, and a readiness review to find out which of those you need first. No option covers all three. The Directive's duties are: pay information for applicants (Art 5), worker requests for pay information (Art 7) and pay gap reports by headcount (Art 9). Each EU country applies them through its own law.

Sources: Directive (EU) 2023/970, Arts 5, 7 and 9, EUR-Lex. The option comparison below is editorial judgement, not sourced data; no vendor prices or features are stated.

Side by side

Four ways to prepare for the Directive (editorial)
OptionGood forWhere it stopsTypical effort
Law firm or counselWhether the Directive reaches you; how a given EU country applies itDoes not prepare your pay dataPaid hours per question
SpreadsheetSmall headcounts; one country; a first look at pay gapsGets error-prone as workers, countries and pay elements growYour own time
HR or pay softwareOngoing pay data and reporting, once you know what to reportDoes not decide whether a duty applies to youSet-up and licence
Readiness review (concept)A neutral first pass: which duties, which dates, which dataPaylucent is not a product yet; not legal advice; no filingA 20-minute discovery call

Pay gap reporting dates and indicators · Duties checklist

How to choose

  1. Not sure it applies? Start with the scope check, then confirm with counsel. US and UK employers
  2. Know it applies, headcount is 150 or more? First reports are due 7 Jun 2027; start on pay data now. (Art 9)
  3. 100 to 149 workers? First reports are due 7 Jun 2031. (Art 9)
  4. Hiring in the EU? Applicants have the right to the initial pay or range, and you may not ask about pay history. (Art 5)

Check your date by headcount

What this page does not cover

No named vendors, prices or feature claims. National transposition laws and penalties are not covered. Dates come from the Directive text as checked on 8 Nov 2026; confirm with counsel and each country's law.

Frequently asked questions

Do we need a law firm to comply with the EU Pay Transparency Directive?

The Directive does not require any particular adviser. Each EU country applies it through its own national law, so a lawyer is the usual route for questions about how a specific country applies a rule. Counsel can confirm scope and national detail; it is not a legal requirement to hire one.

Can a spreadsheet handle pay gap reporting?

For a small headcount, it can hold the numbers. The Directive's pay gap report covers seven indicators and a split by categories of workers (Art 9), so the work is mostly in building clean, comparable pay data. Whether a spreadsheet is enough depends on how many workers, countries and pay elements you have.

What does a readiness review do?

It is a neutral first pass: which duties could apply to you, which dates, and which data you need. Paylucent is a concept in validation and offers only a discovery call about that idea. It is not a product and not legal advice.

What is the first report date I should plan for?

Under Art 9, first reports are due 7 Jun 2027 for employers with 150 or more workers and 7 Jun 2031 for 100 to 149 workers. National laws can differ, so check each country.

Sources: Directive (EU) 2023/970, Arts 5, 7, 9. EUR-Lex

Talk it through

We are testing whether a neutral readiness review is useful. Book a discovery call to tell us where you employ and hire.

Request a readiness review (concept)