⚖️ Directive (EU) 2023/970 · national implementation under way across the EU

Is your organisation ready for pay transparency?

Employers will have to demonstrate that women and men are paid equally for equal work and work of equal value, using objective criteria, analysis and explainable pay decisions. Find out in ten minutes where your organisation stands.

12 questions · about 10 minutes Your points of attention, straight away No salary data required A one-hour advisory session with the full Equal Pay Check
2023/970
The EU Pay Transparency Directive, in force since June 2023
7 June 2026
Deadline for member states to transpose the Directive into national law
5%
Unexplained pay difference triggering a joint pay assessment. Not a tolerance threshold: smaller unjustified differences must be addressed too
Now
The data you will report on is being built today
The Equal Pay Check was tested by
Bidfood Damsté advocaten en notarissen Emondt FC Twente Mediq Mees van den Brink

Six organisations helped build the Equal Pay Check by going through the whole process and sharing their experiences and suggestions on the questions, the outcomes and the report.

What users say about the Equal Pay Check
“This gives us a clear picture of where work still needs doing, and of how to go about it.”
“Very welcome to get an overview like this without having to hand over GDPR-sensitive information.”
“A few details that are easy to step over were brought out by the Check after all.”
“As far as I can judge, every relevant theme was covered.”
“The questionnaire was easy to complete. We were done within 15 to 20 minutes.”

From the evaluations by the test organisations, translated from Dutch. Unattributed at their request.

The rules

What the Pay Transparency Directive changes

Directive (EU) 2023/970 applies across the Union; each member state sets its own implementation. These are the four things it asks of you. The dates below are the Dutch ones, as an example.

1

Transparency before hiring

You share the salary or salary range before the first discussion of terms, for instance in the vacancy. And you may no longer ask candidates about their pay history.

This applies in principle to employers of any size, including those with no reporting duty.

2

Information rights for employees

Employees gain the right to information about their own pay level and about average pay levels for colleagues doing equal or equivalent work, broken down by sex.

You need a process for that, and you must tell employees the right exists. Clauses preventing employees from discussing pay are not permitted.

3

Reporting on the pay gap

Larger employers report periodically on pay differences between women and men. In the Netherlands, employers with 150 or more employees report by 7 June 2028 on calendar year 2027; those with 100 to 149 by 7 June 2031.

Thresholds and dates differ per member state. Check what applies in the countries where you employ people.

4

The 5 per cent threshold

If reporting shows an unexplained difference of 5 per cent or more within a category of workers, and it is not corrected within six months, a joint pay assessment with workers' representatives follows.

Five per cent is not a tolerance level. A smaller difference you cannot objectively explain may still be unjustified.

Where does it stand? The directive entered into force in 2023 and the transposition deadline passed on 7 June 2026. Member states are at different stages. In the Netherlands, bill 36949 was submitted to parliament on 21 May 2026, with intended entry into force on 1 January 2027; it still has to pass both chambers, so dates and thresholds may change. Follow the Dutch bill on tweedekamer.nl ↗
Where do you start?

The key questions right now

Five questions come up in HR, executive and compliance teams. The Equal Pay Check answers all five, starting from your own situation.

?

Where do we start?

The check works through the five areas the Directive touches and gives you a prioritised starting point instead of a list of separate obligations.

?

Are we ready?

You see per theme whether the foundation is in place, whether it is not yet explainable, or whether it is missing altogether.

?

Do we have a problem?

The check shows where the risk sits: placement on hiring, recruitment, progression, transparency or data. Including readiness for the 5% threshold.

?

How much work is this?

Every point of attention becomes a concrete measure with a proposed owner, priority and starting phase. You know what is urgent and what can wait.

€

What will it cost?

The check itself is free to start and €995 excl. VAT for the full report with action plan and a one-hour advisory session, with a €500 introductory discount until 25 November. More importantly, you see in advance where further investment is needed, in policy, job architecture, data or communication, so you can budget precisely instead of buying broadly.

What the check assesses

The Directive's requirements, made practical

The Equal Pay Check works through the areas where you will need to show that pay is objective and explainable.

  • ✓
    Objective job evaluationIs work of equal value defined using gender-neutral criteria?
  • ✓
    Transparent pay criteriaAre scales, ranges and growth criteria clear and explainable?
  • ✓
    Analysis by category of workersCan you surface differences within comparable job groups?
  • ✓
    Pay gap reportingIs your HR and payroll data able to produce the required figures?
  • ✓
    The 5% thresholdDo you know what to do at an unexplained difference of 5% or more, and below it?
  • ✓
    Documentation and evidenceWhich records are missing to justify pay decisions?
  • ✓
    Employee rights and representationIs the information request process in place, and are representatives involved?
  • ✓
    Remediation and action planWhich steps do you take, who owns them and in what order?

What you actually receive

Full Equal Pay Check: 20 to 25 minutes to complete · report within 24 to 72 hours · advisory session, 1 hour (online), by arrangement
  • Your readiness score per theme
  • Where differences are likely to arise
  • Missing documentation and records
  • Findings ranked by urgency
  • A prioritised action plan with an owner per measure
  • An executive summary for decision-making
  • Advisory session, 1 hour (online) with a reward systems adviser, who talks you through the report and answers your questions
The Equal Pay Check is a self-assessment tool: it maps what you need to arrange and gives you the action plan. It is not a certification, audit or legal opinion, and it offers no guarantee of compliance.
Often overlooked

Three things to arrange now

Threshold
5%

The 5% trigger

Where an unexplained pay difference within a category of workers reaches 5% or more, has no objective justification and is not corrected within six months, a joint pay assessment with employee representatives follows. Note: 5% is not a tolerance threshold. Smaller unjustified differences must be addressed as well. The check tests whether you can calculate this and whether you have a scenario ready.

Representation
WC

Employee representation

Pay transparency touches trust and industrial relations. In a joint pay assessment, employee representatives are a required partner. The check looks at whether representatives are structurally involved in pay policy. Early involvement prevents that conversation from happening under time pressure.

Board
▤

Board reporting

The report includes an executive summary: score, main risks, first measures and the decision requested. Ready to use in a management meeting, supervisory board or audit committee, so ownership and budget are assigned rather than left open.

Timeline

From Directive to reporting duty

The Directive sets the framework. Each member state sets its own dates in national law.

2023May

Directive adopted

Directive (EU) 2023/970 on pay transparency and enforcement of equal pay enters into force.

2026June

Transposition deadline

Member states were required to transpose the Directive into national law by 7 June 2026. Several states, including the Netherlands, did not meet that deadline.

2026now
You are here

National implementation under way

Implementing legislation is in progress across the EU. Obligations, thresholds and dates take effect through the national law that applies to your organisation.

2027onwards

Transparency obligations apply

Pay ranges when recruiting, the ban on asking about pay history, accessible pay criteria and employee information rights come into effect as national laws enter into force.

2027+

First pay gap reports

Larger employers report on the gender pay gap, with the first reporting year and deadline set nationally. In the Netherlands, for example, the bill provides for a first report by 7 June 2028 covering calendar year 2027 for employers from 150 people.

Status based on public sources, August 2026. National implementing legislation is still in progress and may change. Check the position for your own country and legal entity.

International Equal Pay Day

18 September: equal pay for work of equal value

The United Nations has marked 18 September as International Equal Pay Day since 2019. It is a fixed, symbolic date that recognises the ongoing effort towards equal pay for work of equal value, worldwide.

18 Sep
A fixed date, set by the United Nations

Globally, women are paid around 20 per cent less than men. International Equal Pay Day is not calculated from that figure; it is a fixed day for reflection and action, supported by UN Women and the International Labour Organization.

Read more on un.org

National Equal Pay Days are calculated, and therefore move

Many countries also mark their own Equal Pay Day: the point in the year from which women effectively work unpaid, given the average pay gap. Because it is derived from that gap, the date shifts each year. The Netherlands is shown here as an example.

1 January to 25 November: paid equally
10%
Netherlands · 25 November
JanFebMarAprMayJunJulAugSepOctNovDec
Period of equal pay Unpaid due to the pay gap: 25 Nov to 31 Dec

Based on the most recently established Dutch pay gap of 10 per cent: 10% × 365 days = 36.5 unpaid days, counted back from 31 December.

The five themes

The check follows familiar HR processes

01

Pay foundation

Job architecture, work of equal value, scales and ranges.

02

Hiring

Vacancies, pay ranges, pay history and starting salaries.

03

Growth & progression

Appraisal, promotion, salary growth and leave effects.

04

Transparency

Information rights, communication, representation and managers.

05

Data & action planning

Data quality, mean and median, the 5% scenario, governance.

Who is it for?

One check, four perspectives

HR

HR leadership & management
  • Is the job architecture current?
  • Are pay scales explainable?
  • Do differences arise at hiring?
  • Are promotion criteria clear?

Executive board

Board & compliance
  • Are we exposed?
  • Which measures come first?
  • What capacity is needed?
  • Which decisions are needed now?

Finance & payroll

Reward & data
  • Base pay and variable pay
  • FTE, role and scale
  • Categories of workers
  • Mean and median differences

Representatives

Works council & unions
  • How is pay determined?
  • What happens at a 5% difference?
  • What information do we receive?
  • Where is this discussed?
Investment

Full Equal Pay Check

One amount for the check, the report and a one-hour advisory session.

was €1,495, now €995 excl. VAT

€500 introductory discount, from Equal Pay Day to Equal Pay Day: 18 September to 25 November 2026. You pay on invoice, which you receive together with the report.

You receive a clear picture of where your organisation stands, and an action plan that names who is responsible for each step. A day of consultancy buys you a conversation. This investment buys you a structured analysis, a substantiated report and a plan that HR, the board and finance can act on the same morning. Start free with the Quick Scan and pay only when you want the full report.

  • Question set across five themes
  • Readiness status per theme
  • Findings ranked by urgency
  • Assessment against the 5% threshold
  • Missing documentation identified
  • Prioritised action plan
  • An owner per measure
  • Executive summary
  • Advisory session, 1 hour (online)
Start the Equal Pay Check
or start with the free Quick Scan →
Frequently asked questions

Good to know

Directive (EU) 2023/970 requires employers to share pay information before recruitment, stops them asking candidates about pay history, gives employees the right to information about pay levels, and requires larger employers to report on the gender pay gap. Member states set the detailed rules in national law. Read the Directive on EUR-Lex ↗

The Directive sets phased duties, with the heaviest obligations for the largest employers. The exact thresholds and dates follow from national implementing law and differ between member states. Below those thresholds, the principle of equal pay and the transparency requirements in recruitment still apply.

The Directive applies to employers in EU member states. Organisations based elsewhere with employees in the EU can fall within the scope of the national law of the country where those employees work. The check is useful in either case, but have the legal position for your entity confirmed by a specialist.

About ten minutes: 12 questions on the essentials. You receive an immediate indication of your main points of attention.

The regular price is €1,495 excl. VAT. From 18 September to 25 November 2026 you pay €995 excl. VAT, a discount of €500. That covers the full question set, scores per theme, the findings, the action plan and the executive summary.

You do not pay in advance and no payment provider is involved: you confirm the order with a digital signature and receive the invoice together with the report, with payment terms as set out in our general terms and conditions.

Allow 20 to 25 minutes; that is what our test organisations needed on average. You can stop along the way; your answers are saved. The report follows within 24 to 72 hours, after review by an adviser. We then schedule the advisory session, 1 hour (online).

Advisory session, 1 hour (online). After the report we schedule an hour with a reward systems adviser. We go through the outcome with you: where the score comes from, which findings really matter and where to start. You can bring in your own situation; the instrument does not know your context, so we ask about it.

The session is included in the price and is not a sales call. You decide who joins, for instance someone from the board or from finance.

No. The check works from self-reporting on your policy, processes and data setup. No individual salary data is requested or processed.

No, and we do not claim that. The check maps what still needs to be arranged and gives you a prioritised action plan. Carrying out those measures is what moves your organisation towards compliance; the check is the starting point and the steering instrument.

Where an unexplained pay difference within a category of workers reaches 5% or more and is not corrected in time, the Directive provides for a joint pay assessment together with employee representatives. Five per cent is not a tolerance threshold: smaller unjustified differences must be addressed as well.

English and Dutch. Both versions use exactly the same questions, scoring and logic, so results are comparable across countries and entities.

Who you will meet

The team behind Equal Pay Check

Your report is reviewed by a person and discussed with you. Here they are.

Gabriella Kourieh
Gabriella Kourieh
Madelon Klippel
Madelon Klippel
Sterre Schrijver
Sterre Schrijver
Marc Altink
Marc Altink
Wob ten Hoeve
Wob ten Hoeve

Know where you stand in ten minutes

The rules are coming. The data you will report on is being built today. Start with insight, end with an action plan.