The United Kingdom requires employers with 250 or more staff to publish gender pay gap figures annually on a public register. The EU Pay Transparency Directive introduces reporting across member states with thresholds phasing in by employer size and first reports expected in 2027. The United States has no equivalent federal requirement. All of these are disclosure regimes rather than prohibitions — they oblige an employer to publish a number, not to change it.
The United Kingdom, and what a public register actually gives you
Employers with 250 or more employees must calculate and publish gender pay gap figures each year, covering mean and median hourly gaps, bonus gaps, the proportion of men and women receiving a bonus, and the distribution of men and women across four pay quartiles. The figures go on a government register that anybody can search by employer name, free, without an account. That accessibility is the point of the design rather than an incidental feature.
The quartile data is the most useful part and the least discussed. A mean or median gap is a single number that can be moved by a handful of senior salaries, whereas the quartile distribution shows you where men and women actually sit in the organization. An employer with a small median gap and a heavily male top quartile is telling you something the headline figure conceals.
Because reporting has run since 2017, the register also carries a time series for most large employers. A single year is a snapshot; five or eight years shows whether anything is moving, and that trajectory is considerably more informative about an employer than the current figure alone. An employer whose gap has closed four points in five years is doing something; one flat since 2017 has published eight numbers and changed nothing.
The European Union
The Pay Transparency Directive introduces gender pay gap reporting across member states, with thresholds phasing in so that the largest employers report first and smaller ones follow. First reports are expected in 2027, which means the machinery is fully specified and entirely untested. Anybody describing how it will work in practice is describing a design rather than an outcome, and the first real evidence is still a year away.
What distinguishes it from the UK regime is the joint pay assessment. Where a report shows an unjustified gap of at least five percent in any category of workers and the employer has not corrected it within six months, the employer must conduct an assessment jointly with worker representatives. That converts disclosure into a process with somebody on the other side of the table, which is a materially stronger design than publication alone.
The complication is that the Directive only bites through national law, and transposition has been slow — only four member states had transposed by the June 2026 deadline. Reporting obligations in most of Europe therefore exist in principle rather than in enforceable form, and the timetable will vary by country for some years yet. So the honest answer to whether an employer in a given member state must report is a national question with a national answer that may change during 2027.
The United States
There is no federal requirement for employers to publish pay gap figures. Some employers publish voluntarily, usually an adjusted figure showing a small residual, and a few states have introduced pay data reporting to a state agency rather than to the public. Those filings inform regulators and researchers without ever reaching a candidate, which is a meaningful difference in what the regime actually does.
That distinction between reporting to an agency and publishing openly matters more than it sounds. Data filed with a regulator informs enforcement and research; data published on a register changes employer behavior through reputation, comparison and recruitment. The two do different work, and only the second is available to you as a candidate.
The practical consequence is that researching a US employer’s pay equity position is genuinely difficult, and most of what you will find is the employer’s own voluntary disclosure — which is nearly always the adjusted figure, presented without the grouping methodology that determines what it means. Asking for the methodology is a fair question and the answer tells you more than the number did.
What reporting does and does not do
What it does is make comparison possible. Once figures are published on a common basis, an employer can be set against its competitors and against its own past, and that comparison operates whether or not any regulator acts. It also forces an internal calculation that many employers had never performed, and the act of calculating is frequently where things get noticed.
What it does not do is require anybody to close a gap. A reporting regime with no assessment trigger obliges an employer to publish an uncomfortable number and nothing more. The UK experience is the clearest evidence: published gaps have moved slowly, which is exactly what a disclosure-only mechanism would predict.
That is the reasoning behind the EU’s assessment trigger, and it is the design difference worth watching over the next few years. Whether adding a procedural consequence to disclosure produces faster movement is a real empirical question that will have an answer by the end of the decade. It is one of the few places in employment policy where two jurisdictions have adopted deliberately different designs for the same objective, which makes the comparison unusually clean.
Using published figures as a candidate
Where a register exists, look the employer up before an interview. It takes a minute and it gives you something few candidates have: a factual basis for a question about progression rather than a vague impression. Most candidates arrive with neither, so it also signals that you research an employer before joining it.
Read the quartiles rather than the headline, and read the trajectory rather than any single year. One year is a snapshot that a reorganization can move; a five-year line is a description of how an organization actually behaves. Then, if you want to raise it, the useful question is not about the number but about what sits behind it — “I noticed the upper quartile distribution; what does progression into senior roles look like here?” That is a question about your own career prospects that happens to be grounded in published data, and it is a reasonable thing to ask anybody.
Where no register exists, the substitutes are weaker but real. An employer’s own published diversity or pay reporting tells you what it chose to disclose. The seniority distribution visible on a professional network gives you an unofficial version of the quartile data. Neither is authoritative and both are better than nothing.
This is general information about how these regimes work rather than legal advice. Thresholds, timetables and national implementations are all in motion, particularly across the EU, so the relevant government register or labor ministry is the place to confirm anything current.
Common questions
Who must report in the UK?
Employers with 250 or more staff, annually, publishing mean and median hourly gaps, bonus gaps, the proportion receiving a bonus, and the distribution across four pay quartiles.
Which UK figure is most useful?
The quartile distribution. A median gap can be moved by a few senior salaries, while the quartiles show where men and women actually sit — a small gap with a heavily male top quartile tells you something the headline conceals.
What does the EU Directive add?
The joint pay assessment. An unjustified gap of at least five percent that is not corrected within six months requires an assessment conducted with worker representatives, which is stronger than publication alone.
When do EU reports start?
First reports are expected in 2027, with thresholds phasing in by employer size. Transposition has been slow — only four member states met the June 2026 deadline.
Does the US require reporting?
Not federally. Some employers publish voluntarily, usually an adjusted figure, and a few states require reporting to a state agency rather than to the public.
Why does agency reporting differ from publication?
Data filed with a regulator informs enforcement and research. Data on a public register changes behavior through reputation and comparison — and only the second is available to you as a candidate.
Does reporting close gaps?
Not by itself. A disclosure-only regime obliges an employer to publish an uncomfortable number and nothing more, and UK gaps have moved slowly, which is what that design would predict.
How should I use a published figure?
Read the quartiles rather than the headline and the trajectory rather than the year, then ask what progression into senior roles looks like — a career question grounded in published data.