The EU's gender pay gap stands at 11.1%. Yet many employers are still waiting for national legislation before preparing for the EU Pay Transparency Directive. Leading employment law firms have a clear message: waiting is not a strategy.
The EU Pay Transparency Directive is changing how employers measure, explain, and report pay differences.
Although the June 7, 2026 transposition deadline has passed, implementation across EU Member States remains uneven. Some countries have introduced legislation, while others are still finalizing national requirements.
For employers, this creates uncertainty about specific obligations and deadlines.
But one thing is clear: the work required to prepare for pay transparency cannot be completed overnight.
Why employers should not wait for EU Pay Transparency legislation
In its June 2026 briefing, international law firm Mayer Brown stated:
“Employers should not wait for national implementing legislation.”
The firm's guidance emphasizes that clear pay structures, reliable data, and strong governance take time to establish.
Similarly, Lewis Silkin's July 2026 analysis, EU Pay Transparency Directive 2026: no EU-level delay and no time for employers to wait, highlights the need for employers to prepare despite differences in national implementation.
For employers operating across several EU countries, waiting for every national law to be finalized risks compressing essential preparation into an increasingly short period.
The opportunity is to use this time to:
- Assess the quality and completeness of payroll and HR data.
- Establish defensible worker categories based on equal work or work of equal value.
- Identify and investigate gender pay gaps.
- Review pay structures and supporting documentation.
- Prepare processes for employee Right to Information requests.
- Build reporting capabilities across relevant EU countries.
National implementation delays provide more time to prepare. They do not eliminate the work that needs to be done.
The EU gender pay gap is 11.1%. What does that mean for employers?
According to Eurostat's Key figures on Europe – 2026 edition, women in the EU earned an average of 11.1% less per hour than men in 2024.
The figures also reveal significant differences between EU countries.
| Country | Gender pay gap |
|---|---|
| EU average | 11.1% |
| Ireland | 8.2% |
| Malta | 4.9% |
| Poland | 4.0% |
| Romania | 3.7% |
| Belgium | 0.7% |
| Luxembourg | −0.8% |
Source: Eurostat, 2024 unadjusted gender pay gap data.
Luxembourg is the only EU country in these figures where women earned slightly more per hour than men on average.
Five EU countries recorded gender pay gaps below 5%.
These differences demonstrate that pay inequality varies considerably across national labor markets.
However, a national gender pay gap is not the same as an employer-level equal pay assessment. It measures differences in average gross hourly earnings, not whether people performing equal work or work of equal value receive equal pay.
For employers, the real question is:
Do you have the data and processes needed to understand pay differences within your own organization?
Ireland's gender pay gap: Why employers should prepare now
Ireland's gender pay gap stands at 8.2%, below the EU average but still representing a measurable difference in average hourly earnings.
As Ireland progresses toward implementation of the EU Pay Transparency Directive, employers have an opportunity to strengthen their preparation.
Irish law firm A&L Goodbody has emphasized that the direction of travel is certain and employers should use the additional time to prepare.
This preparation involves more than calculating an overall gender pay gap.
Employers need to understand differences within worker categories, assess the factors contributing to those differences, and establish processes for providing accurate information when requested.
Waiting until national requirements are finalized may leave less time to address data gaps, inconsistencies, or unexplained differences.
What happens when an employee requests pay information?
One of the Directive's important changes is the introduction of stronger employee rights to pay information.
Under Article 7, workers will be entitled to request information about their individual pay level and average pay levels, broken down by sex, for categories of workers performing the same work or work of equal value.
The Directive provides a two-month response period for these requests.
Actual applicability and implementation will depend on the relevant national legislation.
For employers with multiple legal entities, payroll providers, and HR systems, retrieving consistent information may be challenging.
Consider an employer managing payroll across several EU countries.
Employee records may sit in one HR system, payroll information in multiple local systems, and job classifications in separate spreadsheets.
When an employee requests information, the organization needs more than an isolated payroll report.
It needs reliable data, appropriate worker categories, and a consistent process for preparing and validating its response.
The first employee request is not the time to discover that your data is fragmented.
Five actions employers can take now
1. Bring payroll and HR data together
Identify where relevant employee and compensation information is stored, how it is structured, and whether it can be compared consistently.
2. Review worker categories
Establish categories that support comparisons of equal work or work of equal value, using objective, gender-neutral criteria.
3. Identify and investigate gender pay gaps
Analyze differences, understand contributing factors, and identify where further investigation or remediation may be necessary.
4. Prepare Right to Information workflows
Define how requests will be received, validated, processed, and answered within applicable deadlines.
5. Establish ongoing visibility
Pay transparency preparation should not depend on a single annual reporting exercise. Regular monitoring can help employers identify issues earlier and maintain more reliable information.
How Lecora helps employers prepare for EU Pay Transparency
Lecora, powered by Payslip, helps employers move from fragmented payroll and HR information to a more structured approach to EU Pay Transparency reporting.
Built on the Payslip Global Payroll Data Foundation, Lecora supports four essential activities:
Prepare: Bring together and standardize payroll and HR data across relevant EU countries and legal entities.
Analyze: Identify, investigate, and understand gender pay gaps across worker categories.
Report: Prepare country-specific gender pay gap reports using more consistent data and processes.
Respond: Manage employee Right to Information requests through a centralized workflow.
For HR, Total Rewards, Compensation & Benefits, Payroll, and Compliance teams, this provides a foundation for greater visibility and more coordinated preparation.
The time to act is now
The EU Pay Transparency Directive is not simply another reporting obligation.
It represents a shift toward greater accountability for how employers structure, explain, and communicate pay.
National implementation may vary, but the underlying preparation challenges are already clear.
Reliable data takes time to establish. Pay differences take time to investigate. Reporting and employee response processes take time to develop.
The longer employers wait, the less time they have to prepare.
Don't wait for legislation to expose the gaps in your data and processes.
Book a demo of Lecora and start preparing for EU Pay Transparency today.
Frequently Asked Questions
Directive (EU) 2023/970 introduces requirements intended to strengthen equal pay through greater transparency, employee information rights, reporting, and enforcement.
The EU transposition deadline of June 7, 2026 has passed. Implementation in individual Member States varies, but there has been no EU-wide extension of that deadline.
According to Eurostat's 2024 data, the EU's unadjusted gender pay gap is 11.1%.
Eurostat's Key figures on Europe – 2026 edition reports Ireland's 2024 unadjusted gender pay gap as 8.2%.
No. Employers can begin improving data quality, assessing pay differences, reviewing worker categories, and preparing reporting and information-request processes before all national requirements are finalized.
Employers can start by standardizing payroll and HR data, defining worker categories, analyzing pay gaps, documenting pay structures, and developing reporting and employee response workflows.
