Rights & obligations · What depends on what

Some obligations you can meet next month. Others need a foundation first.

The four obligations do not start from the same place. Pay ranges for applicants need bands; information requests and reports need groups of equal work and one reliable dataset.

What each obligation needs first

Art. 5 · EUR-Lex Art. 6 · EUR-Lex Art. 7 · EUR-Lex Art. 9 · EUR-Lex

Obligation	What it asks	What must exist first	Effort	Can start
Before hiring (Art. 5)	Pay range or starting pay to applicants; no salary-history questions	Pay bands per role; agreed wording for recruiters	Low	Now
Accessible criteria (Art. 6)	Criteria for pay, pay levels and progression, objective and gender-neutral	A written pay system and a decision on how much to publish	Medium	After reviewing the pay system
Right to information (Art. 7)	Own pay and average pay by sex for the same work or work of equal value, within two months	Groups of equal work, a reliable dataset, a response process with owners and deadlines	High	After job evaluation
Reporting (Art. 9)	Defined gap metrics, mean and median	Groups of equal work, a reliable dataset, a metric definition and a sign-off cycle	High	After job evaluation

Information requests and reports stand on the same foundation: groups of equal work and one reliable dataset. Build it once.

How the pieces connect

Reporting frequency by headcount

Art. 9 · EUR-Lex

Employees	Frequency	First report
250 and more	Annually	7 June 2027
150–249	Every three years	7 June 2027
100–149	Every three years	7 June 2031
Below 100	No obligation under the Directive	Member states may go further

The four obligations in detail

Art. 5

Before hiring

Pay ranges for applicants and no salary-history questions.

Art. 6, 7

During employment

Accessible criteria and the right to information.

Art. 9, 10

Reporting & joint pay assessment

Gap metrics and what follows a gap of 5% or more.

Art. 10

Works council

Where worker representatives come in.