Pay transparency: graduated obligations and deadlines for employers

Equal Opportunities – Discrimination
Pay Transparency: Differentiated Obligations and Progressive Deadlines for Companies

The pay transparency decree introduces a system of obligations graduated according to company size, with the aim of making the gender pay gap progressively monitorable. Certain obligations apply to all employers. These include the requirement to state the starting salary or relevant pay band in job advertisements, the prohibition on asking candidates about remuneration in previous employment, and the obligation to make accessible to workers the criteria used to determine pay.
The more substantial obligations concerning the collection and reporting of gender pay gap data apply exclusively to employers with at least 100 employees. Companies with at least 250 employees must carry out their first assessment by 7 June 2027 and thereafter on an annual basis. Companies with between 150 and 249 employees are also required to submit their first report by 7 June 2027, but with subsequent updates every three years. For employers with between 100 and 149 employees, the obligation will take effect from 7 June 2031, with triennial reporting.
Where the data collected reveals, within a category of workers, an average pay differential between men and women of at least 5% that is not justified by objective criteria and has not been corrected within six months, the employer will be required to initiate a joint pay assessment with workers” representatives, aimed at identifying and eliminating the disparities.