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Guide

The EU Pay Transparency Directive: A Multi-Country Payroll Readiness Playbook

Manage legal entities, payroll data, and national reporting calendars within a single control model.

The EU Pay Transparency Directive (2023/970) establishes a common minimum framework, but the implementation date, reference period, and reporting deadline may differ by country. While one legal entity within a multinational group may be preparing for the 2026 reference year, another entity may be subject to a later reporting timeline.

This guide covers the seven metrics required under Article 9, the payroll data needed, and entity-level scope determination. It explains how to harmonize local pay components within a common data dictionary, schedule employee representative consultation ahead of reporting, and initiate the review process where a gender pay gap of 5% or more is identified.

  • Separate Reporting Calendars for Each Country

  • Payroll Data Required for Article 9

  • Q4 2026 Preparation Plan

  • From Single-Country to Global Payroll

The EU Pay Transparency Directive: A Multi-Country Payroll Readiness Playbook

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