EU Pay Transparency Starter — educational checklist pack for Directive (EU) 2023/970
Pay Transparency Starter is a downloadable readiness pack for SME owners and HR leads preparing for Directive (EU) 2023/970 — pay transparency and equal pay for equal work or work of equal value — as transposed into national law. It is not legal advice, not HR software, and not a certification.
Price: $39.90 USD one-time. Checkout is via Polar (card in USD). After payment, Polar emails the receipt and file download to the email you use at checkout. This site does not store card data.
Who it is for
- SME owners who employ people in one or more EU Member States and need a structured first pass with HR / counsel
- HR or People leads updating job ads, intake forms, and pay-structure documentation
- Teams approaching the Art. 9 reporting thresholds (100+ workers on the Directive timeline)
Official dates used in this pack (EUR-Lex / Commission)
| Date | What (summary) | Article |
|---|---|---|
| 7 June 2026 | Member States must transpose the Directive into national law. | Art. 34(1) |
| From national law | Applicants’ right to initial pay / pay range; employers must not ask about pay history; gender-neutral vacancy notices. Detail and start date depend on national transposition of Art. 5. | Art. 5 |
| 7 June 2027 | First gender pay-gap reports: 250+ workers (annually thereafter); 150–249 workers (every three years thereafter). | Art. 9(2)–(3) |
| 7 June 2031 | First gender pay-gap reports: 100–149 workers (every three years thereafter). | Art. 9(4) |
| After reporting | If any category shows an ≥ 5% average pay difference that is not justified on objective, gender-neutral criteria and is not remedied within six months → joint pay assessment. | Art. 10(1) |
Equal-value pay structures must enable comparison using objective, gender-neutral criteria including skills, effort, responsibility, and working conditions (Art. 4(4)). Employers with fewer than 100 workers: voluntary reporting under Art. 9(5); Member States may require more under national law.
National law varies. Many Member States missed the 7 June 2026 transposition deadline. Day-one hiring duties land when national law applies them. Check your Member State — this page does not invent a country-by-country table.
Sources (verify live): EUR-Lex Directive (EU) 2023/970, ELI / OJ, European Commission — EU action for equal pay.
What is in the pack (v1)
- START-HERE (EN) + short German companion
- Job-ad / applicant pay-info checklist — vacancy pay range + no salary history (Art. 5)
- Pay-structure checklist — categories of workers & equal-value criteria (Art. 4)
- Who must report — headcount thresholds, first dates, 5% joint assessment (Art. 9–10)
What this does not mean
Checking boxes does not make you “pay-transparency compliant.” National transposition, collective agreements, and your facts matter. Use official sources and qualified counsel for decisions that affect workers’ rights or filings. This pack does not calculate your gender pay gap or produce a statutory report.
Educational materials only. Not legal advice. Not HR software. Not a certification. Pay Transparency Starter does not guarantee legal or compliance outcomes. Operator: Ismail Kanto.