In this Coffee Talk Special, Henrike von Platen speaks with Margrét Vilborg Bjarnadóttir about the reporting logic under Article 9 of the EU Pay Transparency Directive. The discussion focuses on which employers are covered, which data points must be reported, how the reporting timeline works, and why the reporting framework matters from a pay governance perspective.
A central point in the conversation is that Article 9 does not apply to all employers. According to the exchange, the reporting obligation is relevant for employers with 100 or more employees. The timing is also clarified carefully. While Member States are to transpose the directive into national law by June 2026, the first reporting deadline discussed in the exchange is 7 June 2027. In practical terms, this means that 2026 functions as a preparation and data collection period rather than as the first year of external submission.
The discussion also makes clear that Article 9 is built around total compensation rather than base salary alone. This includes fixed pay, variable pay, and benefits. That distinction is described as important because benefits have not always been included consistently in pay gap calculations. Against that backdrop, the external reporting requirement is presented as six distinct data elements. These include the mean gender pay gap based on total compensation, the mean gender pay gap in variable pay, the median gender pay gap, and the median gender pay gap in variable pay. In addition, employers are to report the proportion of women and men receiving variable pay and the gender distribution across pay quartiles. The quartile requirement is described as a way of looking beyond averages by ordering employees according to total compensation, dividing them into four equal groups, and showing the proportion of women and men in each quarter of the pay distribution.
Alongside the six external reporting elements, the conversation identifies a seventh element that is relevant for internal reporting only. This concerns the calculation of the gender pay gap within each category of worker. At the time of the exchange, the definition of such categories is described as still uncertain, with the expectation that the applicable rules will become clearer once national implementation is further developed. The discussion also outlines the staggered rollout set out in the directive. As described in the exchange, employers with 250 or more employees are expected to report from 2027 on an annual basis, employers with 150 to 249 employees from 2027 every three years, and employers with 100 to 149 employees from 2031 every three years.
From a governance perspective, the exchange presents Article 9 as a structured transparency mechanism rather than a narrow reporting formality. The emphasis falls on having reliable compensation data, including benefits, and on preparing the underlying data structure early enough to support consistent reporting. The conversation also notes that immediate enforcement consequences are not fully addressed in detail, but it does point to the likelihood that public visibility and the identification of non-reporting organizations may create pressure once reporting becomes operational. In that sense, the reporting framework is described as relevant not only because it requires disclosure, but because it creates a basis for comparison and scrutiny across organizations.