The United Kingdom requires employers with 250 or more employees to publish gender pay gap figures annually on a public register. The EU Pay Transparency Directive brings reporting to member states, with the first reports due in 2027 for larger employers. There is no federal US pay gap reporting requirement, though several states impose their own pay data reporting.
The United Kingdom
Employers with 250 or more employees publish mean and median gender pay gaps, bonus gaps, the proportion receiving a bonus, and the distribution of men and women across pay quartiles. It goes on a public government register anyone can search, which is what gives it force — the data is comparable and permanent.
The European Union
Directive 2023/970 requires reporting by employer size, phased in, with the first reports due in 2027. Where an unjustified gap of at least five per cent appears in a category of workers and is not remedied, the employer must conduct a joint pay assessment with worker representatives — a mechanism that goes beyond publication into obligatory action.
It applies only as member states transpose it, and as of the June 2026 deadline most had not.
The United States
No federal requirement. A federal collection of pay data by sex, race and job category ran briefly and was discontinued. Several states require their own pay data reporting from larger employers, and those obligations were unaffected by the 2025 revocation of the federal contractor executive order.
What reporting does and does not do
Publication is a disclosure regime, not a prohibition. An employer with a large published gap has broken no law by having one. What it creates is comparability — between employers, and for the same employer year on year, which is harder to explain away than a single number.
Using published figures as a candidate
Where a register exists, look up an employer before you interview. A wide gap alongside a well-written diversity statement is a useful thing to know, and the quartile distribution usually tells you more than the headline figure does.
Common questions
Which countries require pay gap reporting?
The United Kingdom for employers with 250 or more staff, and EU member states as they transpose Directive 2023/970, with first reports due in 2027.
Does the US require it federally?
No. A federal collection of pay data by sex and race ran briefly and was discontinued. Several states have their own requirements.
What is a joint pay assessment?
Under the EU directive, where an unjustified gap of at least five per cent appears and is not remedied, the employer must assess pay jointly with worker representatives.
Is having a gap unlawful?
No. Reporting is a disclosure regime rather than a prohibition, and a published gap is not itself a breach.
Can I look up an employer?
In the UK, yes — the figures sit on a public register. The quartile distribution usually tells you more than the headline number.