Four months after the EU deadline, most member states are still legislating. The bills now before parliaments share a design choice that changes who produces the number: several governments intend to calculate most pay-gap figures themselves, from data employers already file through payroll. The arithmetic leaves the pay-equity tool. The judgement stays with the employer.
The deadline for transposing the EU Pay Transparency Directive was 7 June 2026. By Deloitte's count, published on 15 October, four member states met it: Italy, Lithuania, Malta and Slovakia. Greece followed with a law taking effect on 1 November. Denmark reintroduced its bill, L 68, on 8 October and held the first reading in the Folketing on 22 October. France's bill is in the Senate under the accelerated procedure, with no committee date set. The Dutch plenary debate is scheduled for the second week of January. Germany had not published a draft when Baker McKenzie reviewed its position on 24 September.
The usual reading of all this is delay, and most employer guidance stops there: wait for the final texts, then configure. That misses what the texts which do exist have in common. The directive tells employers to report their gender pay gaps. Several national bills move most of the calculation to the state, and build it on the payroll filings employers already make.
The state takes the arithmetic
Finland is the clearest case. Under government bill HE 129/2026, Statistics Finland would compile six of the seven required pay-gap indicators from the Incomes Register, the national database every Finnish payroll already reports into. Guidance the Incomes Register published on 30 September turns fields that were optional into requirements: wages itemised by income type, full-time or part-time status, regular weekly hours and part-time percentage. For employers with 150 or more staff, that additional reporting starts on 1 January 2027, the date the bill is due to take effect.
The Netherlands takes a similar route. The draft decree uses as its starting point the wage for wage tax and national insurance purposes as declared in the payroll tax return, adjusted for holiday allowance so that one-off payments do not distort the comparison. In France, the bill's indicators are to be partly automated "à partir des données issues de la DSN", the monthly payroll declaration, according to Deloitte's French employment team. Denmark's earlier draft, published in February before a general election interrupted it, had Statistics Denmark and employer organisations preparing pay reports on companies' behalf from existing occupation-coded pay statistics. The reintroduced bill sends reports to a new Labour Market Institute for Equal Pay.
The details differ and some will change in parliament. The direction is consistent. In these countries the headline pay-gap figures a regulator or works council sees will come out of the payroll feed, processed by a public body, and not out of the pay-equity software HR bought to produce them.
The directive was written as a disclosure duty for employers. In several capitals it is being built as a data-quality duty for payroll.
Two numbers, built on different foundations
That matters because the two calculations start from different places. Pay-equity analysis inside HR usually works from the compensation record: base salary, target bonus, contracted hours, annualised. A payroll filing records what was actually paid in the period, coded by income type, against the hours declared. Bonus timing, leavers, retrospective adjustments, allowances coded under the wrong income type and part-time hours entered once at hire and never updated all push the two apart.
Under the Finnish bill, the one figure left to employers is the category-level gap: pay differences between women and men doing the same work or work of equal value, split into basic pay and complementary or variable pay, hourly and annual, calculated separately and submitted to Statistics Finland. That is also the figure that carries consequences. The Dutch, Danish and Bulgarian drafts all tie a joint pay assessment to an unexplained category gap of 5% or more. An employer could therefore find itself defending a category analysis built on HRIS compensation data, next to an official headline figure built on payroll filings, with no reconciliation between them. Employee representatives will notice before the regulator does.
Figure 1
Country | Status, mid-October 2026 | Where the official figures start | What stays with the employer | First data year (largest employers) |
|---|---|---|---|---|
Finland | Bill HE 129/2026 before Parliament; proposed in force 1 January 2027 | Incomes Register filings; Statistics Finland compiles six of seven indicators | Category-level gaps, calculated and submitted to Statistics Finland | 2027, reported by 2 May 2028 |
Netherlands | Bill in parliament; plenary debate due second week of January 2027 | Wage for tax and national insurance in the payroll tax return, adjusted | Report submission; job evaluation and classification | 2027, reported in 2028 |
France | Bill no. 944 in the Senate, accelerated procedure, no committee date | Partial automation from DSN payroll data announced; method set by decree | Equal-value indicator, phased by size; current Index runs through 2027 | New regime from 2028 |
Denmark | Bill L 68 introduced 8 October; first reading 22 October; proposed effect 1 March 2027 | Reports to a new Labour Market Institute for Equal Pay; occupation codes (DISCO) or equivalent | Worker categories, if not using DISCO | 2027, reported by 1 September 2028 (250+ staff) |
Germany | No draft published as of late September; law not expected before early 2027 | Not yet defined | Not yet defined | Reporting not expected before June 2028, per the ministry |
Same directive, different pipes. Compiled from Deloitte (15 October 2026), Ius Laboris (30 September 2026), the Finnish Incomes Register guidance as reported by Trusaic (13 October 2026), Meijburg & Co on the Dutch draft decree, Deloitte France (23 September 2026), the French Senate record and Baker McKenzie (24 September 2026). All drafts are subject to change in parliament.
What stays behind is the hard part
A statistics office can divide total pay by total hours. It cannot tell which of your jobs are of equal value, because it does not know your job architecture. So the split the bills create is uneven. The state takes the arithmetic that can be automated; the employer keeps the classification that has to be defended. The Netherlands requires job evaluation and classification. Croatia's labour ministry has published a voluntary job evaluation methodology built on the directive's four criteria: skills, effort, responsibility and working conditions. Denmark allows DISCO occupation codes, though PwC's Copenhagen team noted when the first bill was published that DISCO is often too coarse to compare jobs of equal value.
For the systems, the requirement that follows is plain. The worker category has to live somewhere authoritative, almost always the HRIS, and payroll has to carry the same code and the same worker identifier. Otherwise the category analysis cannot be reconciled with the headline figure the state publishes from the same people's pay.
The reporting year starts before the laws do
The timetable is the uncomfortable part. In Finland, the Netherlands and Denmark, the first reports for the largest employers cover calendar year 2027. The pay data those reports will draw on starts accumulating on 1 January, while the Dutch bill still awaits its plenary debate and Denmark's second reading has no date. Payroll fields corrected in March will not fix January's filings.
Year end is also the worst time to ask for change. Payroll teams are in freeze, and multinationals often run a separate in-country provider in each market. A new mandatory field becomes a change request to several vendors in their busiest quarter. Germany is the exception that misleads: with reporting not expected before June 2028, a group that plans to the German timetable will be late everywhere else.
Before the 2027 payroll year opens
For each EU country where you employ 100 or more people, record which filing the authority will read: Incomes Register, payroll tax return, DSN, occupation-coded statistics, or not yet decided.
Name an owner for each payroll field that feeds it: income-type coding, contracted and actual hours, part-time percentage, variable pay.
For one country, recompute the headline gap from payroll output and compare it with your pay-equity tool. Explain the difference before anyone else asks.
Decide where worker categories are mastered, and confirm payroll carries the same category code and worker identifier.
Ask each in-country payroll provider when it will support the new fields, and what its year-end change window is.
Treat the list as live. Dates in the Netherlands, Denmark, France and Spain may move before January.
Whose desk this lands on
Total Rewards usually owns pay-equity methodology. Payroll owns the fields the state will read, and in many groups payroll reports to finance or a shared-services centre rather than to HR. HRIS owns the job architecture. The directive's obligations sit with the employer regardless of which function holds which piece, so the CHRO needs one owner, per country, for a simple question: which number will the authority calculate about us, from which filing, and does it agree with ours?
For many European employers, the first official pay-gap figure published about them will be one they did not calculate. It is worth seeing it before anyone else does.
Sources and notes. Deloitte Legal, "EU Pay Transparency Directive: transposition update as of 12 October 2026", Kathryn Dooks and Deepinder Lamba, 15 October 2026. Ius Laboris, "EU Pay Transparency Directive: which countries have transposed", 30 September 2026. Trusaic, "Finland's Incomes Register publishes pay transparency guidance", 13 October 2026, and "Finland submits EU pay transparency bill to Parliament" (government bill HE 129/2026 vp). Meijburg & Co, "Dutch pay transparency draft decree under consultation", 24 June 2026. Deloitte Société d'Avocats, "Directive Pay Transparency: le projet de loi franchit une nouvelle étape", 23 September 2026. French Senate, projet de loi no. 944 (2025-2026), deposited 10 September 2026, accelerated procedure. DCI Consult on the Senate referral, updated 21 October 2026. MK Law on the first reading of the Danish bill, 22 October 2026; Zenegy on bill L 68; PwC Denmark on the February 2026 draft, 3 March 2026. Baker McKenzie, "Germany: missed Pay Transparency Directive implementation deadline", 24 September 2026. The description of how HR pay-equity tools typically calculate is editorial assessment, not survey data. HRHubsMedia has no commercial relationship with any firm named. Journalism, not legal or procurement advice. Corrections welcome.
