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Pay Transparency

Pay Transparency Directive for SMEs

Pay Transparency Directive for SMEs: salary ranges, pay history ban, information rights, pay criteria, reporting thresholds and evidence plan.

Direct answer

The Pay Transparency Directive requires EU employers to prepare salary-range disclosure, remove pay-history questions, support worker pay-information rights, document objective pay criteria, and meet pay-gap reporting where thresholds apply. SMEs should update hiring templates and retain evidence before national laws take effect.

What does the Pay Transparency Directive require from SMEs?

The Pay Transparency Directive requires EU employers to prepare salary-range disclosure, remove pay-history questions, support worker pay-information rights, document objective pay criteria, and meet pay-gap reporting where thresholds apply. SMEs should update hiring templates and retain evidence before national laws take effect.

  • Add salary ranges
  • Remove pay history questions
  • Document pay criteria
Transposition deadline2026-06-07
Core hiring taskSalary range disclosure and pay history removal
Reporting thresholdPay-gap reporting starts at 100+ workers under phased rules

The Pay Transparency Directive requires EU employers to prepare salary-range disclosure, remove pay-history questions, support worker pay-information rights, document objective pay criteria, and meet pay-gap reporting where thresholds apply. SMEs should update hiring templates and retain evidence before national laws take effect.

2026-06-07Transposition deadline

EU member states must transpose Directive (EU) 2023/970 into national law.

Source: European Commission equal pay and pay transparency guidance

Pay Transparency Directive for SMEs checklist

Action checklist
Add salary ranges

Prepare role ranges for job adverts or pre-interview disclosure.

Article 5

Remove pay history questions

Update recruiter scripts, application forms and agency instructions.

Article 5

Document pay criteria

Record objective, gender-neutral criteria for pay and progression.

Articles 6-7

Key deadlines

DateRequirementSource
2026-06-07Transposition deadlineEU member states must transpose Directive (EU) 2023/970 into national law.European Commission equal pay and pay transparency guidance
2027-06-07First reporting for larger employersFirst reports are due for employers above certain headcount thresholds.European Commission equal pay and pay transparency guidance

30/60/90-day action plan

First 30 days

Confirm scope and assign an owner

Evidence needed: Applicability note, business owner, systems or product list, and source links.

Pay Transparency Directive

Days 31-60

Close the evidence gaps

Evidence needed: Policies, supplier records, data maps, technical notes, training records, or process owners.

Pay Transparency Directive

Days 61-90

Prepare for audit or customer review

Evidence needed: Versioned compliance file, action log, exception register, and next review date.

Pay Transparency Directive

Evidence to retain

Applicability decision

Shows whether Pay Transparency Directive readiness applies and why the SME made that decision.

Retain: Scope memo, trigger criteria, country notes, owner approval, and review date.

Action owner list

Regulators and enterprise customers expect named accountability, not generic intent.

Retain: Owner, backup owner, due date, status, and unresolved blocker notes.

Evidence folder

The fastest way to answer customer due diligence is a single audit-ready evidence file.

Retain: Policies, screenshots, registers, exports, supplier responses, and training records.

SME questions answered

Does Pay Transparency apply to small employers?

Some obligations apply broadly to employers, while pay-gap reporting is phased by headcount. National laws can add stricter rules.

What should SMEs do first for Pay Transparency?

Update job advert templates, remove pay-history questions and document salary range methodology.

Turn this guide into a tracked action plan

Start with the Regulation Checker, save the result, and import the action plan into your EuroComply dashboard when you are ready to assign owners.

EU salary range job ads checklistEU salary range job ads checklist for SMEs: role bands, objective criteria, recruiter scripts, agency instructions and evidence under Pay Transparency.Pay gap reporting checklistPay gap reporting checklist for EU employers: headcount thresholds, worker categories, pay components, 5% gap trigger and evidence.EU compliance deadlines 2026 for SMEsTrack the 2026 EU compliance deadlines SMEs should prepare for: Pay Transparency, AI Act, PPWR, CRA reporting, e-invoicing, and accessibility evidence.

Informational only. This page is not legal advice and does not replace a qualified legal review of your business, systems, products or employment practices.