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 deadline | 2026-06-07 |
| Core hiring task | Salary range disclosure and pay history removal |
| Reporting threshold | Pay-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.
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 checklistPrepare role ranges for job adverts or pre-interview disclosure.
Article 5
Update recruiter scripts, application forms and agency instructions.
Article 5
Record objective, gender-neutral criteria for pay and progression.
Articles 6-7
Key deadlines
| Date | Requirement | Source |
|---|---|---|
| 2026-06-07 | Transposition deadlineEU member states must transpose Directive (EU) 2023/970 into national law. | European Commission equal pay and pay transparency guidance |
| 2027-06-07 | First 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.
Informational only. This page is not legal advice and does not replace a qualified legal review of your business, systems, products or employment practices.