Gender pay-gap reporting in 2027: what to do with your 2026 pay data

June 14, 2026 · 7 min read

Here's the part that catches people out: the first EU gender pay-gap reports aren't due until 2027, but they're built on 2026 pay data. The payroll you're running right now is the number that will be measured. By the time the report is due, the data is already set — so the work to make it defensible has to happen this year.

What's due, and when

Under the EU Pay Transparency Directive (Directive (EU) 2023/970), gender pay-gap reporting is phased by headcount. Using 2026 pay data, the first reporting wave lands in 2027:

• 250+ employees: report annually; first report due 7 June 2027.
• 150–249 employees: report every three years; first report due 7 June 2027.
• 100–149 employees: report every three years; first report due 7 June 2031.

Employers with fewer than 100 staff aren't required to report, though the Directive's hiring-transparency and pay-information rules still apply to them. Source: Ogletree Deakins.

What the report actually has to contain

It's not a single headline number. Employers must report, broken down by sex:

• The gender pay gap (mean and median).
• The gap in complementary or variable pay components (bonus, commission, benefits).
• The proportion of female and male workers receiving those variable components.
• The proportion of female and male workers in each quartile pay band.
• The pay gap between categories of workers doing the same work or work of equal value, split by base salary and variable pay.

That last line is the one that takes preparation: it forces you to define which roles count as "equal or equivalent work" before you can calculate anything. Source: Littler.

The 5% trigger

If the report shows an unjustified gap of 5% or more in any category of worker — one you can't explain on objective, gender-neutral grounds — you're required to carry out a joint pay assessment with worker representatives and take corrective action. This is why finding gaps early matters: a gap you discover in 2026 is a problem you can fix before the report; a gap you discover in the 2027 report is a compliance obligation with a clock on it. Source: Littler.

If you also report in the UK

The UK runs its own, separate regime — and it's been in force since 2017. Employers with 250 or more relevant employees on the snapshot date (5 April for private and voluntary sector, 31 March for public sector) must publish their gender pay-gap figures within a year: by 4 April the following year for the private sector, 30 March for the public sector. The UK is not covered by the EU Directive, so groups operating on both sides will run two methodologies in parallel. Source: GOV.UK.

What to do in 2026 — before the data is locked

• Define your worker categories now. Decide what counts as "equal or equivalent work" — the unit the gap is measured in. Get this wrong and every downstream number is wrong.
• Run a dry-run gap analysis on your current 2026 data, by category, including variable pay. Treat it as a rehearsal for the real report.
• Investigate any 5%+ gaps while you can still act on them. Either justify them with objective, documented criteria, or close them.
• Check data quality. Reliable sex, role, level, and full-pay-relevant flags in your HR system are what the whole report depends on.
• Confirm the rules for each country you operate in. Member states transpose the Directive into national law individually, and details (and timelines) vary.

How Remunara helps

The reporting is the easy part — it's the preparation that decides whether the number is defensible. Our pay equity & transparency service defines your worker categories, runs the gap analysis on your 2026 data, and helps you close or justify gaps before they become a 2027 obligation. The platform then keeps the analysis live, so each year's report is a button, not a project.

This article is general information, not legal advice. The EU Directive is transposed into national law country by country, and the UK regime is separate — confirm the specifics for each jurisdiction you operate in.

Sources

• EUR-Lex — Directive (EU) 2023/970 (full text)
• Ogletree Deakins — The EU Pay Transparency Directive's Progress Explained
• Littler — The EU Pay Transparency Directive
• GOV.UK — Gender pay gap reporting: when to report