Reporting deadlines: who reports in 2027, and who reports in 2031
The gender pay gap reporting duty in Article 9 does not switch on for everyone at once. It phases in by employer size, and each band has both a first deadline and a reference pay year. Miss the reference year and you plan against the wrong data, so both matter.
The phase-in, band by band
| Workers | First report by | On data from | Then |
|---|---|---|---|
| 250 or more | 7 June 2027 | 2026 | Every year |
| 150 to 249 | 7 June 2027 | 2026 | Every three years |
| 100 to 149 | 7 June 2031 | 2030 | Every three years |
| Fewer than 100 | Not required | n/a | Voluntary only |
Why the reference year is a year earlier
The Directive says the first report is provided by its deadline relating to the previous calendar year. So the 250+ and 150 to 249 bands, reporting by 7 June 2027, report on 2026 pay data, and the 100 to 149 band, reporting by 7 June 2031, reports on 2030 data. The practical point for a reward team is that the reference year is happening now or has already passed by the time you build the report. If you are in a 2027 band, your 2026 pay data is the input, so the quality of that data is fixed by how you record it this year.
The cadence splits the two 2027 bands. A 300-person employer reports every year from 2027. A 200-person employer reports in 2027 and then not again until 2030, because its cadence is every three years. Same first deadline, very different ongoing workload.
What a late national law does to the date
Member states had to transpose by 7 June 2026 under Article 34, and most missed it. The reporting deadlines above still stand, because they are set in the Directive. What a national law can do is set an earlier date, add detail on how to count and categorise workers, or, through gold-plating, widen who is caught. Lithuania, for example, has extended reporting toward all employers with monthly pay reporting. That is why your country's status is part of a firm answer, not an afterthought.
Backward-plan from your deadline
Once you know your band, work backwards. If you report in 2027 on 2026 data, you need clean, categorised pay data for 2026 in place now, a dry-run gap calculation well before the deadline, your job architecture defined so you can group workers into categories doing equal work, and the pre-employment rules live from national transposition. The paid country report lays this out as a dated checklist for your member state, and the free checker gives you the band and reference year to start from.