How to comply with the Pay Transparency Directive: a checklist for businesses
30 September 2026
Penalties for pay transparency: what non-compliant companies stand to lose
1 October 2026
1 October 2026
Reporting obligations regarding pay transparency: who must disclose what
On 26 June An in-depth session was held on a topic that is becoming increasingly important for organisations: pay transparency. The key speakers at the meeting were Filippo Cannavò (Head of HRO Service & Training at Alveria) and Andrea Ferrante (CRO of Quiris Holding), who shared the company’s approach to transforming a regulatory requirement into a strategic lever for the evolution of the HR function.
From compliance to organisational opportunity
One of the key messages to emerge from the speech is clear: Pay transparency cannot be treated as a mere compliance requirement. Reducing it to mere “compliance” means exposing oneself to high risks, because organisational complexity does not lend itself to superficial interpretations. As Andrea Ferrante points out, transparency is “a ticking time bomb” if left unmanaged: it can generate tensions and misunderstandings, but it represents an extraordinary opportunity if managed as a genuine change management project. In this sense, Quiris Holding has chosen to use the European Directive as a driver of transformation, taking this opportunity to accelerate a transition that is already underway: the shift from a family-run business to a managerial organisation.
The “Beyond Pay Transparency” project”
This approach has been put into practice in the project “Beyond Pay Transparency”, which enabled Quiris Holding to secure a significant recognition to the HR Innovation Awards, in the category “A data-driven and proactive HR management approach”. The project was launched against a backdrop of strong business growth and aims to develop a more objective, transparent and data-driven people management model. It is therefore not simply a matter of analysing remuneration, but of fundamentally rethinking the entire organisational system.
The enabling role of technology
A key element of the process was the adoption of the platform HCMS of Alveria, which has made it possible to:
- to map organisational roles in a structured way
- to form homogeneous clusters of positions
- to analyse and monitor pay discrepancies
- distinguish between explained and unexplained gaps
This data-driven approach not only enables us to identify any discrepancies, but also to understand their causes. The ability to explain pay differentials is, in fact, a crucial step, particularly when these exceed certain thresholds or become the subject of regulatory scrutiny.
The starting point: positions, not levels
Another important insight concerns the starting point of the analysis: not the contractual level, but the organisational position. As Filippo Cannavò has pointed out, limiting oneself to the levels set out in the national collective labour agreements risks obscuring critical issues, such as cases where a position is classified below its actual value.
For this reason, it is essential to adopt a “double vision”:
- on the one hand, regulatory and contractual constraints
- on the other hand, an organisational assessment based on skills, responsibilities and working conditions
Internal equity, external benchmarks and company policies
The project also highlighted the need to distinguish between:
- internal equity, relating to the consistency between roles and pay
- external equity, based on a comparison with the market
Companies are required to draw up their own policy on the weighting of positions, by determining the relative weighting of factors such as skills, responsibilities and seniority. There are no strict regulatory constraints in this regard: it is a strategic and cultural choice.
Transparency and organisational culture
A central theme One issue that emerged during the meeting concerns the management of internal communication. Transparency, in fact, inevitably gives rise to questions and discussions amongst staff. If left unmanaged, this dynamic can lead to the creation of “information gaps” which are filled by personal perceptions and beliefs. As Ferrante points out, it is essential not to leave these gaps unfilled, but to manage them through tools, data and structured communication.
A HR transformation driver
The Quiris case demonstrates how the integration of data, technology and organisational culture can drive a new evolution of the HR function.
Pay transparency works as follows:
- a means of achieving greater fairness
- a catalyst for organisational change
- a tool to support managerial decision-making
- a key factor in attracting and retaining talent
Ultimately, moving “beyond compliance” represents a strategic choice: transforming a regulatory obligation into a tangible opportunity to build organisations that are more aware, better structured and more sustainable.
CONSULTANCY, TRAINING, HR DIGITALIZATION AND CORPORATE SOLUTIONS, DISCOVER THE ALVERIA METHOD. GET READY FOR CHANGE.
In summary
- Employers with at least 100 employees must report data on the gender pay gap (Legislative Decree 96/2026, Article 9).
- For organisations with 250 or more employees, the reporting is annual; for those with between 100 and 249 employees, it is every three years.
- Seven indicators are reported: average and median gaps, variable components, quartiles and gaps by category of worker.
- The data is sent to the monitoring body at the Ministry of Labour, following consultation with workers’ representatives.
Reporting obligations regarding pay transparency These provisions apply to employers with at least 100 employees, who are required to report data on the gender pay gap in accordance with Directive (EU) 2023/970 and Legislative Decree 96/2026. We often hear the term ’pay transparency’ used, but the legislation employs the technical term ‘remuneration transparency’. This guide to reporting the gender pay gap explains who is required to report, how often, and what data must be disclosed, how to prepare the report and whoever receives it.
Who is required to report on the gender pay gap: obligations by company size
Who is required to produce the gender pay gap report? Employers, whether in the public or private sector, with at least 100 employees (Legislative Decree 96/2026, Article 9): the obligation to report on the gender pay gap depends on the size of the organisation.
- Level of application. The obligation rests with the individual employer (Article 2); groups with a standardised remuneration policy may aggregate the data at national level (Article 9).
- How to identify the threshold. The decree does not specify a method for calculating the thresholds in the report: it is advisable to define and document this in consultation with your employment adviser.
The mandatory gender pay gap report is changing in terms of frequency, not content:
| Size range | What is being communicated | Frequency |
| 250 employees or more | The seven items of information referred to in Article 9 | Every year (Article 9) |
| 100–249 employees | The same information | Every three years (Article 9) |
| Fewer than 100 employees | No report; other obligations towards candidates and employees remain (Articles 5, 6 and 7) | — |
Pay transparency for companies with between 100 and 249 employees
Under the pay transparency rules, companies with between 100 and 249 employees must disclose, every three years, the same seven items of information set out in Article 9 as are required of larger companies.
- Frequency. Three-year period; the first notification must be made:
- by 7 June 2027, with 150–249 employees,
- by 7 June 2031, with 100–149 employees.
- Because it matters. With regard to pay transparency for companies with more than 100 employees, the criteria and data sources may change over the next three years.
An example: In a manufacturing company with 180 employees, the HR department extracts the annual salaries from the payroll and, using the HR system, links them to gender, national collective agreement level and category. The employment consultant checks the entries, and the decisions are set out in a methodology note, to be included in the next communication.
Pay transparency for companies with 250 or more employees
However, in order to comply with pay transparency requirements, companies with 250 or more employees must disclose the information specified in Article 9 annually, with the first disclosure due by 7 June 2027.
- Compared with the previous price range. The only thing that changes is the frequency: annual rather than triennial.
- What does this involve?. Pay transparency reporting is becoming a recurring process, with the same data and rules each year.
- What is the best course of action?. Manage data and criteria in a repeatable and documentable manner: scope, pay components, categories, method versions.
For these recurring communications, many companies are considering a pay transparency software which retains the method and data history.
What data to provide: the information referred to in Article 9 of the Directive
Article 9 of Directive 2023/970 sets out seven items of information on the pay gap, which are reproduced under the same letters (a) to (g) in Article 9 of Legislative Decree 96/2026. These gender pay gap indicators Article 9 sets out in detail what data must be disclosed regarding the pay gap.
| Information | What does it measure? | Letter (Article 9) |
| Gender pay gap | Difference between the average pay levels of women and men | (a) |
| Discrepancy in supplementary or variable components | The same applies to bonuses and other variable components | (b) |
| Median gender pay gap | Difference between the average pay of women and men | (c) |
| Median gap* in complementary or variable components | Median difference in bonuses and variable remuneration | (d) |
| Percentage of women and men receiving variable pay components | Variation between the two genders | (e) |
| Percentage of women and men in each pay quartile* | Distribution of the two genders across the four pay bands | (f) |
| Gap by category of worker* | Difference in pay between those carrying out the same work or work of equal value, broken down into basic and variable pay | (g) |
- Medium and median. The average gap is influenced by extreme salaries; the median describes the person in the middle of the distribution.
- Quartiles. They show whether one of the two genders is concentrated in the lowest income brackets.
- Categories of workers. The gap between them is the figure that comes closest to a “like-for-like” comparison.
How to prepare a gender pay gap report: required data and standard structure
A report template on the gender pay gap requires reliable data and a structure that remains consistent over time.
Initial data
- Sources. Payroll, personnel records, organisation (positions, national collective agreement levels, categories).
- Remuneration items. Basic pay and supplementary or variable components (Article 9).
- Reference period. The same applies to all data.
- Who is responsible for this?. HR and personnel administration, with IT handling data extraction and the employment consultant carrying out checks.
With data coming from different systems, collection and consolidation are the most labour-intensive part: a software for reporting on the gender pay gap reduces the number of manual steps.
Standard structure of a report on the gender pay gap
- Reference period. Start and end dates.
- Staff. Employees by gender and scope.
- Information required by the standard. The seven items of information referred to in Article 9.
- Methodological notes. Items included, criteria for categories, part-time work and absences, exclusions.
Most common mistakes
- Pay components vary from one year to the next.
- Part-time figures are not shown on a comparable basis.
- Categories based solely on the job title.
- An undocumented method, which is difficult to explain to staff representatives.
Monitoring body: to whom is the data disclosed?
The body responsible for monitoring pay transparency collects and publishes data on the pay gap and monitors the implementation of equal pay (Directive 2023/970, Article 29; Legislative Decree 96/2026, Article 14).
- People in Italy. A body within the Ministry of Labour, comprising representatives from public authorities, institutions and the social partners (Legislative Decree 96/2026, Article 14).
- What you receive. The information referred to in Article 9, of which the information set out in points (a) to (f) is published (Article 14).
- How they are transmitted. The procedures for data collection, including electronic methods, are to be laid down by decrees of the Minister for Employment (Article 9).
- Before sending. The employer shall confirm the accuracy of the data after consulting the employees’ representatives (Article 9).
Frequently Asked Questions
Should the pay gap figures reported by companies be published?
To some extent, yes: the monitoring body publishes the information set out in points (a) to (f) of Article 9 (Legislative Decree 96/2026, Article 14). The employer may also publish this information on their own website, but is not obliged to do so (Article 9). Data relating to the remuneration of an identifiable employee remains confidential (Article 11).
How is the number of employees calculated for the pay transparency thresholds?
It depends on the threshold. For 50 employees the decree It refers to the criteria set out in the Workers’ Statute and Legislative Decree 81/2015 (Article 6). It does not specify a threshold for the report (100, 150 and 250): the method must be agreed with the employment consultant.
Should the report on the gender pay gap be produced for each company or for the group as a whole?
As a general rule, for each company: the obligation applies to the individual employer (Legislative Decree 96/2026, Article 2). However, a group with a standardised remuneration policy may aggregate the data at national level (Article 9), explaining the rationale for this choice in the methodological notes.
Reporting obligations regarding pay transparency: from data to report
We can show you how Alveria Pay Transparency supports the collection, analysis and documentation of the pay gap for your reporting purposes.