Directive (EU) 2023/970
Pay transparency: what changes and how to prepare
The EU Pay Transparency Directive brings pay ranges into recruitment, gives employees the right to information about pay and requires reporting of the gender pay gap. The first reports cover 2026, so this year's data already matters.
Status in Romania · 9 October 2026
The transposition law has not been adopted yet
The transposition deadline was 7 June 2026. Bill L445/2026 is being debated in the Senate, the first chamber, and may still change before adoption. Until the law enters into force, the directive does not create direct obligations for private employers.
The principle of equal pay for equal work or work of equal value, however, is already set out in the Romanian Labour Code (Art. 6(3)).
What the directive requires
Six changes for employers
Pay before hiring
Candidates receive the starting pay or the pay range of the job, in the job advert or before the interview. Employers can no longer ask about previous salaries.
Right to information
Employees can request their own pay level and the average levels, by sex, for their category of workers. The answer is due within two months at most.
Objective criteria
The criteria for setting pay and pay progression must be objective, gender-neutral and accessible to employees.
Gap reporting
Employers with at least 100 workers periodically report indicators on the pay gap between women and men.
Joint pay assessment
If a category of workers shows an average gap of at least 5% that is not objectively justified and not remedied within six months, a joint assessment with workers' representatives follows.
Burden of proof
In pay discrimination disputes, the employer must prove there was no discrimination. The directive also provides for compensation and penalties.
Reporting timeline (Art. 9)
Each report covers the previous calendar year
The first report, in June 2027, is based on 2026 payroll data. A correct report needs a frozen employee population for the year and pay components reconciled with payroll.
Deadline for transposing the directive into national law.
First report, for 2026: annually for 250+ workers; every three years for 150–249 workers.
First report for employers with 100–149 workers, then every three years.
Voluntary reporting under the directive; national law may extend the obligation.
What is reported
The directive's seven indicators
The indicators are calculated for the employer's whole workforce, and the last one also by categories of workers doing the same work or work of equal value.
The exact reporting format in Romania and the authority it is submitted to will be set by the transposition law and its implementing rules.
- Gender pay gap (mean)
- Gender pay gap in variable or complementary components (mean)
- Median gender pay gap
- Median gender pay gap in variable or complementary components
- Proportion of women and men receiving variable components
- Proportion of women and men in each pay quartile
- Pay gap by category of workers, broken down by base pay and variable components
How HRImage helps
A report suite for preparation and analysis
The pay transparency reports in Data Image, the Business Intelligence module, use payroll and HR data directly. Use them monthly to find data issues early, and the gaps that will need explaining.
Employer-level indicators
Mean and median gaps for total pay and variable components, with monthly and annual trends.
Pay quartiles
Composition by sex of each quartile, calculated on annual values per worker, not on payroll lines.
Analysis by category
By division, department, organisational unit, job category and family, working hours and tenure.
Gaps to investigate
Categories with gaps above a chosen threshold, for example 5%, as a starting point for justification or correction.
Data readiness
Population included, missing or invalid sex, unmapped pay components, job categories not yet evaluated.
Documented methodology
Every report describes the period, population, formula and limitations, so the results can be explained.
Job categories and data that is not in payroll
Job evaluation by skills, responsibility, effort and working conditions usually does not exist in the payroll system. With Data Image imports you add evaluated categories, pay grades or other information from an Excel file, matched on the employee badge or the position, and use them in reports right away.
Confidentiality
General reports show aggregated values only. Small groups can be suppressed, and data-level permissions mean each user sees only the population they have access to.
Data imports in Data ImageThe reports support data preparation and analysis. They do not constitute legal advice and do not certify legal compliance. The final reporting format will be aligned with the Romanian transposition law once it is adopted.
What you can do now
Four steps to your first report
Check the data
Sex recorded for every employee, correct contract history, working hours and hours worked.
Classify pay components
What is base pay and what is variable: allowances, bonuses, premiums, benefits.
Define categories
Group jobs doing work of equal value, using objective, gender-neutral criteria.
Analyse and explain
Identify gaps of at least 5% and document the justification or corrective measures.
Frequently asked questions
Pay transparency in brief
Do we have to report in 2026?
No. Under the directive, the first reports are due by 7 June 2027 and cover 2026. The specific obligations for employers in Romania will follow from the transposition law, which is still being debated in Parliament. The 2026 data, however, will be the basis of the first report.
What does "work of equal value" mean?
Different jobs can be of equal value if they require comparable skills, responsibility, effort and working conditions. Grouping must use objective, gender-neutral criteria, not job titles or current salaries.
What counts as pay?
The directive defines pay broadly: base salary and any other benefits in cash or in kind received directly or indirectly from the employer, such as allowances, bonuses, premiums and benefits.
What happens if there is a gap above 5%?
A gap does not automatically mean discrimination. If the average gap in a category of workers is at least 5%, is not justified by objective, gender-neutral criteria and is not corrected within six months of reporting, the employer carries out a joint pay assessment with workers' representatives.
Can we use HRImage reports if we do not use IQ.HR payroll?
Yes. Payroll data can be loaded through file imports and the reports are configured to your structure. For clients already using HRImage payroll, the data is available directly.
Sources: Directive (EU) 2023/970, EUR-Lex · Bill L445/2026, Romanian Senate. Information as of 9 October 2026, for general guidance only.
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