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Gender pay gap report template for the EU Pay Transparency Directive

A gender pay gap report under Article 9 of Directive (EU) 2023/970 is a short set of numbers: mean and median gaps, gaps in variable pay, who gets variable pay, quartiles and the gap per category of workers [1][5]. Below is a template you can copy, the data you need, and a worked example.

Who has to report, and when

The directive sets three groups by headcount [1][2][3]:

Member States may set lower thresholds, so a smaller employer can still be covered by national law [3]. Employers under 100 workers may report voluntarily [4]. Countries had to turn the directive into national law by 7 June 2026 [6], and several are late. Your national law decides the exact form, the reporting body and the reference period, so check it before you file.

What goes in the report

Article 9(1) lists the indicators. Secondary guides that map them agree on this set [1][5][7]:

1. The gender pay gap (mean).
2. The gender pay gap in complementary or variable pay (mean).
3. The median gender pay gap.
4. The median gender pay gap in complementary or variable pay.
5. The proportion of female and male workers who receive complementary or variable pay.
6. The proportion of female and male workers in each quartile pay band.
7. The gender pay gap between workers by categories of workers.

The last item is the one that matters most in practice. If a category shows an average gap of at least 5%, the employer cannot justify it with objective, gender-neutral criteria, and does not fix it within six months, a joint pay assessment with worker representatives follows (Article 10) [1][8][9].

The data you need

One row per worker, for the reference year. Keep it minimal:

• Worker ID (not the name)
• Sex
• Category of workers (same work or work of equal value)
• Annual base pay
• Annual variable or complementary pay (bonus, commission, allowances)
• Annual hours, so you can compare hourly pay for part-time and full-time staff

Your categories should rest on objective, gender-neutral criteria such as skills, effort, responsibility and working conditions [7]. Job titles alone are often too narrow or too broad. Write down how you grouped the roles, because you will need to explain it if a gap shows up.

Worked example

A company has a category "Customer support, level 2" with six workers. Hourly base pay (annual base pay divided by annual hours):

Average for women: (21.00 + 22.00 + 23.00) / 3 = EUR 22.00. Average for men: (22.50 + 24.00 + 25.50) / 3 = EUR 24.00. In this example the gap is expressed as a share of men's average pay: (24.00 minus 22.00) / 24.00 = 8.3%. The medians are EUR 22.00 and EUR 24.00, so the median gap is also 8.3%.

This category is above 5%. The next step is to look for a reason that is objective and gender-neutral, for example a documented difference in experience level that your pay policy rewards for everyone. If there is no such reason, plan a correction now. Six months goes quickly once the report is out.

Check the exact formula your national law prescribes. Some countries publish a calculation method or a form, and the reference period and pay elements can differ.

Copyable report template

GENDER PAY GAP REPORT
Employer: [legal name]
Reference period: [start date] to [end date]
Number of workers: [n] (women [n], men [n])
Pay elements included: [base pay, bonus, commission, allowances, ...]
Method: [hourly pay = annual pay / annual hours; gap = (men avg - women avg) / men avg]

1. Mean gender pay gap: [x.x]%
2. Mean gap in variable or complementary pay: [x.x]%
3. Median gender pay gap: [x.x]%
4. Median gap in variable or complementary pay: [x.x]%
5. Share receiving variable pay: women [x]%, men [x]%
6. Quartile pay bands (share women / men):
   Lower      [x]% / [x]%
   Lower mid  [x]% / [x]%
   Upper mid  [x]% / [x]%
   Upper      [x]% / [x]%
7. Gap by category of workers (base pay and variable pay):
   [Category]   women avg [x]   men avg [x]   gap [x.x]%
   [Category]   ...

Categories at 5% or more: [list]
Explanation or planned correction per category: [text]
Prepared by: [name, role]   Date: [date]

Common mistakes

• Comparing annual pay across part-time and full-time staff. Use hourly figures, or the gap mostly measures hours.
• Leaving out variable pay. Bonuses and allowances are separate indicators, not an optional extra [1][5].
• Tiny categories. With one woman and one man, a "gap" says more about two people than about your pay system. Note it, and check how your national rules treat small groups.
• Sending raw payroll around. The report only needs the aggregates. Keep the row-level file with as few people as possible.

Related guides

• Salary ranges in job ads under the EU Pay Transparency Directive
• How to answer an employee pay information request
• Spreadsheet, tool or consultant: which way to prepare

Sources

1. Directive (EU) 2023/970, Articles 9 and 10 (EUR-Lex)
2. Addleshaw Goddard, EU Pay Transparency Directive: the requirements (reporting thresholds and dates)
3. PwC Malta, The EU Pay Transparency Directive: key takeaways (thresholds, lower national thresholds)
4. NCPE Malta (national equality body), What is the new Pay Transparency Directive
5. KPMG Hungary, The new EU directive on pay transparency (Article 9 indicators)
6. Clifford Chance, Pay transparency directive (transposition date 7 June 2026)
7. Orbiq, Pay transparency gap analysis template (Article 9(1)(a) to (g), Article 4 criteria)
8. Mondaq, Pay Transparency Directive: what is a joint pay assessment
9. Lexgo, EU Pay Transparency Directive: practical implications for all employers (Article 10)

This guide explains the rules in plain language. It is not legal advice. Check your own country's law and, when in doubt, ask a qualified adviser.