Pay transparency in France: why the 50-employee scope bites harder
France is a good example of why the EU headcount floor is not the whole story. The Pay Transparency Directive sets its reporting duty at 100 workers, but France already regulates pay equality at 50 employees through its Index Egapro, and its draft transposition is expected to keep that lower scope. For an employer with, say, 70 staff in France, that difference is decisive.
The existing regime: Index Egapro at 50
France has for several years required employers with 50 or more employees to calculate and publish an Index de l'égalité professionnelle, known informally as the Index Egapro. It is a five-indicator score covering areas such as the pay gap, the distribution of individual pay rises and promotions, pay increases on return from maternity leave, and the representation of women among the highest earners. Employers publish a score out of 100 and must take corrective action if the score falls below a set threshold.
What the Directive changes
France's draft bill is expected to keep the 50-employee scope rather than move up to the Directive's 100 floor. The main shift is content: the five-indicator Index is set to be replaced by the seven data points the Directive requires under Article 9. So the population of employers stays broad, while the metrics they report become the EU-standard set, including the mean and median gaps, the variable-pay breakdowns, the quartile distribution and the by-category gap that can trigger a joint pay assessment.
The practical effect. Many French SMEs between 50 and 99 employees sit below the EU floor but inside the national scope. They are used to the Index, but the move to the seven data points and to the Directive's other mechanisms, such as the pre-employment rules and the reversed burden of proof, is a genuine step up in obligation. Final implementation is expected in 2027.
Status and the moving picture
As at 12 July 2026, France had not completed transposition by the 7 June 2026 deadline; a draft bill had been disclosed, with final implementation expected in 2027. This is a decaying fact. The exact scope, the mapping of the old Index to the new data points, and the timing can all change as the bill moves through the legislative process, so confirm the current position before you act. Our country report re-verifies France at the date of purchase and flags what is settled versus still in draft.
What to do now if you operate in France
If you have 50 or more staff in France, assume you are in national scope even below the EU 100 floor, keep your Index Egapro obligations running, and start mapping your data to the seven Directive data points so the transition is not a standing start. The pre-employment rules (a pay range before interview, no salary-history questions) and the two-month right to information apply from transposition regardless of size. The free checker flags the France national-floor position, and the paid France report sets out the dated detail and a timeline.