Reporting obligation
Organisations with 100 or more employees must periodically report on pay differences between men and women. If there is a gap of 5% or more without objective justification, a mandatory joint pay assessment follows. Payqual generates these reports, signals risks and lets you download the result when everything is complete.
Last update: February 24, 2026 · Reading time: 7 minutes
What does the law say about reporting?
“Organisations with 100 or more employees must periodically report on the pay gap between male and female workers, per category of equivalent work.”
EU Richtlijn 2023/970, artikel 9
The Pay Transparency Directive sets strict requirements for the frequency, content and public disclosure of pay reports.
Periodic reporting
Organisations with 250+ employees report annually, organisations with 100-249 employees every three years. The first report must be submitted within the legal deadline after entry into force (Directive 2023/970, Article 9).
5% threshold and Joint Pay Assessment
If the difference in average pay between men and women in a category is 5% or more and cannot be objectively justified, a joint pay assessment (JPA) must be conducted within six months (Directive 2023/970, Article 10).
Content requirements
The report must include: the pay gap per category, the gap in supplementary or variable components, the median pay gap, the proportion of men and women receiving supplementary components, and the distribution per quartile (Directive 2023/970, Article 9(1)).
Public disclosure
Certain reporting data must be made publicly available and shared with the supervisory authority.
Sanctions for non-compliance
Member states must establish effective, proportionate and dissuasive sanctions for employers who fail to report or do not meet reporting requirements.
Where do things often go wrong?
Reporting is more than filling in a spreadsheet. These are the most common pitfalls.
Incomplete data
Reporting without including all compensation components (variable, bonus, pension) leads to incorrect conclusions and legal risk.
Missing deadlines
The reporting cycle is strict. Late reporting can lead to sanctions and strengthens employees' position in disputes.
No follow-up at >5%
Identifying a gap but not starting a Joint Pay Assessment within six months is a violation in itself.
Manual errors
Manually collecting data and performing calculations increases the chance of errors that are immediately apparent in an audit.
How Payqual automates reporting
Payqual collects all compensation data, performs the analysis and generates a report that meets all PTD requirements. Risks are flagged so you can act before the report is finalised.
Connect data
Connect your HR and payroll system to Payqual. All compensation components are automatically loaded and categorised.
Analysis and risk signalling
Payqual analyses pay differences per cluster and flags where the 5% threshold is exceeded. You immediately see which categories need attention.
Download report
Once all risks have been assessed and corrected where needed, download the complete report. Ready for the regulator.
Payqual monitors continuously. You don't have to wait until the deadline approaches — risks are flagged immediately when new data becomes available.
Preview your report
Discover what the reporting process looks like. Switch between the different sections of your pay report.
847
Employees
10
Clusters analysed
94%
Compliance score
Q1 2026
Report date
Always up-to-date
Reports are automatically updated when new data becomes available.
One-click export
Download the complete report in the correct format for the regulator.
Audit-ready
Complete audit trail of all analyses, changes and approvals.
Ready to report?
Discover how Payqual helps you deliver your pay report completely and on time.