EU Pay Transparency Directive · Article 9

Your pay gap report, computed on your machine.

Levelbook calculates every indicator the Directive requires from a payroll export, inside your browser. The file never leaves your computer: no upload, no account, no data processing agreement to negotiate.

First reports for employers with 150 or more workers are due 7 June 2027

Orrery Works · 180 workers · analysed locally

(a) Mean gap

…

(c) Median gap

…

Flagged

…

Engineers & senior specialists

(f) Quartile pay bands

of payroll data uploaded

0 bytes

of payroll data uploaded

Article 9(1) indicators, (a) to (g)

7 of 7

Article 9(1) indicators, (a) to (g)

of column headers recognised

5 languages

of column headers recognised

a year per employer, not per head

€490

a year per employer, not per head

The problem

The Directive's dates are set. Most national rules are not.

Article 9 puts the first reports in June 2027, on 2026 pay, and the year being measured is almost over. National laws may shift the first date (Germany's ministry already points to 2028), but the data work is the same either way. Mid-sized employers have the least time and the smallest HR teams, and the tools on the market ask them to upload every salary to someone else's cloud.

  1. 7 June 2026

    Transposition deadline

    Only a handful of Member States had national law in place. The deadline has not been extended.

  2. 7 June 2027

    First reports, 150+ workers

    Covering calendar year 2026. Employers with 250+ workers then report every year, 150 to 249 every three years.

    Next
  3. 7 June 2031

    First reports, 100 to 149 workers

    Then every three years. Member States may go further and require smaller employers to report.

Uploading payroll is a procurement project. A cloud pay-equity platform processes the pay and sex of every worker. That means a data processing agreement, a security questionnaire, a transfer assessment and, often, a works council conversation before you see a single number.

Levelbook removes that step by design. The arithmetic runs in a Web Worker in your browser tab. There is no server that could receive the file, so there is no processor to sign with, no vendor to audit and no vendor copy to leak. You can verify this yourself in your browser's network panel.

How it works

From payroll export to signed report in an afternoon.

Every screen below is the real app, rendered with the fictional sample company.

  1. 01

    Drop in a payroll export

    CSV or Excel, comma or semicolon, headers in English, German, French, Italian or Croatian. Levelbook maps the columns, normalises part-time and mid-year contracts to gross hourly pay, and points to the exact row of anything it can't read.

    Your columnRecognised as
    Employee ID Worker ID
    Gender Sex
    Job title Job title
    Department Department
    Annual base salary (EUR) Annual base pay (gross)
    Annual bonus (EUR) Complementary or variable pay
    Shift allowance (EUR) Complementary or variable pay
    Weekly hours Contractual weekly hours
    Months employed Months employed
  2. 02

    Group jobs into categories of equal value

    Article 4 says categories must rest on skills, effort, responsibility and working conditions. Score each job on those four factors and Levelbook proposes a grouping; you adjust it by hand.

    Machinist

    3434

    Quality inspector

    4342

    Customer service advisor

    3433

    All three land in Skilled production & service: different jobs, equal value.

  3. 03

    See every gap, and which ones cross 5 %

    Mean and median gaps, variable pay, quartile bands and the per-category breakdown, with small groups flagged before they mislead you. Each chart has a table view and works with a screen reader.

  4. 04

    Explain, fix, file

    Record objective justifications and a dated remediation plan for each flagged category, watch the six-month window, then download the Article 9 PDF and a CSV of the indicators. Answer Article 7 requests and check job ads in the same place.

    orrery-works-pay-gap-report-2026.pdf

    Indicators (a) to (g) · category breakdown · explanations · methodology · Art. 9(6) confirmation block

    Built on this device

Privacy by architecture

We can't lose your payroll. We never receive it.

Levelbook is a static web app. Once the page has loaded, the file you open is read by JavaScript in your tab, analysed in a Web Worker and saved in your browser's own storage. The page's Content-Security-Policy only allows connections back to the origin that served it, which hosts nothing but static files.

  • No account needed to analyse.
  • Works offline once loaded: try it with Wi-Fi off.
  • Export the project as a file you control. Delete it from the browser in one click.
  • Self-hostable: the whole product is a folder of static files.
YOUR BROWSER TABpayroll.xlsxread locallyWeb WorkerArticle 9 engineIndexedDB + PDFstays on deviceAny serverblocked by CSP
The file, the engine and the outputs all live inside the tab. connect-src 'self' stops any script from sending data elsewhere.

Try it

Would this category trigger Article 10?

Enter the average gross hourly pay of women and men in one category of workers. A difference of 5 % or more, not justified on objective, gender-neutral criteria and not remedied within six months, requires a joint pay assessment.

Or load a whole sample company

Gap relative to men's pay

+8.1 %

At or above the 5 % threshold. Justify it with objective, gender-neutral criteria or remedy it within six months of reporting.

Women€27.40Men€29.805 % line

Member State status

Where national law stands.

5 of 27 Member States had fully transposed the Directive by the time we last checked. National law sets when your first report is due; the Directive’s dates are the baseline most drafts keep.

Transposition status by Member State, last checked 7 October 2026
Member StateStatusNotes
ATAustriaNo draft publishedExisting law already requires pay reports from employers with 150+ workers.
BEBelgiumPartly transposedFrench Community (public sector) transposed; federal private-sector law pending.
BGBulgariaDraft or bill publishedBill amending the Protection Against Discrimination Act sent to Parliament on 11 Sep 2026.
HRCroatiaNo draft publishedNo draft yet; a voluntary job-evaluation toolkit was published in Sep 2026.
CYCyprusDraft or bill publishedDraft law under consultation.
CZCzechiaDraft or bill publishedGovernment bill before the Chamber; targeted start 1 Jan 2027.
DKDenmarkDraft or bill publishedDraft published; targeted start Jan 2027.
EEEstoniaPartly transposedPartial amendments in force from 13 Jul 2026.
FIFinlandDraft or bill publishedGovernment proposal submitted to Parliament on 9 Jul 2026; targeted start 1 Jan 2027.
FRFranceDraft or bill publishedDraft bill amended in Sep 2026; keeps a 50-worker reporting threshold.
DEGermanyNo draft publishedNo draft bill published; the ministry expects the law in early 2027 and first reports in June 2028.
GRGreeceTransposedLaw adopted 6 Jul 2026; some obligations apply from 1 Nov 2026.
HUHungaryNo draft publishedAdoption is planned for Oct 2026 in the autumn legislative programme.
IEIrelandDraft or bill publishedPartial draft; existing gender pay gap reporting for 50+ workers continues.
ITItalyTransposedLegislative decree adopted before the deadline; implementing decrees follow.
LVLatviaDraft or bill publishedDraft law published.
LTLithuaniaTransposedLabour Code amended; some rights apply from 1 Jan 2027.
LULuxembourgNo draft publishedNo public draft.
MTMaltaTransposedLegal Notice 173 of 2026, published 5 Jun 2026.
NLNetherlandsDraft or bill publishedBill in the House of Representatives; plenary debate expected Jan 2027.
PLPolandPartly transposedRecruitment rules in force since Dec 2025; reporting bill pending.
PTPortugalDraft or bill publishedGovernment bill published 5 Aug 2026.
RORomaniaDraft or bill publishedDraft tabled in the Senate in Jun 2026.
SKSlovakiaTransposedAct adopted Apr 2026; first average-pay reporting in 2028 on 2027 data.
SISloveniaNo draft publishedNo public draft.
ESSpainDraft or bill publishedDraft Royal Decree; consultation closed 24 Aug 2026.
SESwedenDraft or bill publishedDraft published; the government is seeking changes and a later start.

Last checked 7 October 2026 against public trackers (beqom transposition tracker, Ius Laboris country tracker). National law changes quickly and may add obligations beyond the Directive. This table is orientation, not legal advice.

Who it's for

Built for the 100 to 1,000 worker band the 2027 deadline hits first.

Large enough to report, too small for a pay-equity consultancy and a six-figure platform.

HR leads

Run the analysis yourself without waiting on IT security review. Answer Article 7 requests in minutes, with the deadline tracked.

CFOs and finance

See what closing each flagged gap would cost before the board asks. A fixed price you can approve on a card, not a per-head contract.

Payroll bureaus and accountants

Produce white-label reports for every client employer from the payroll exports you already hold, without moving them to a third party.

Pricing

A fixed price. Not per employee.

Per-employee pricing punishes exactly the companies this law reaches. Levelbook costs the same whether you have 150 workers or 950, and you pay for a report as often as the Directive asks you for one.

Early access until 31 January 2027

Try every feature free. PDF reports carry a Draft mark until you have a licence. Founding customers who sign up before the end of early access get 50 % off the first year, with the price locked for 2 years.

Become a founding customer

Analysis

€0forever

Know your numbers before anyone asks.

  • All seven Article 9 indicators on screen
  • Categories of workers and job scoring
  • Indicator CSV export
  • Job ad checker and readiness list
Start now

Single report

€590one-off, per report

For employers with 100 to 249 workers, who report every three years.

  • Article 9 PDF report with methodology
  • Justification and remediation records
  • Article 7 reply letters for 12 months
  • Project files for your records
  • Email support until you file

Between reports: letters and pay-round checks for €129 a year.

Request a licence

Annual

Recommended

€490per employer, per year

For employers with 250 or more workers, who report every year.

  • Everything in Single report, every year
  • Article 7 letters all year round
  • Follow-up after an Article 10 flag
  • Email support from the team that built it
Request a licence

Partner

€1,900per year, up to 25 employers

For payroll bureaus and accountants.

  • Everything in Annual, for every client
  • White-label PDF with your name
  • Bulk import templates for your payroll system
  • Partner onboarding call
Become a partner

No VAT is added: we are not in the Croatian VAT system. Request a licence and we email the invoice within one working day; pay by bank transfer, card or SEPA debit, and the licence file follows by email. Questions first? Contact us.

FAQ

Questions we get asked.

Is this legal advice?

No. Levelbook computes the indicators the Directive defines and drafts documents from your data. Whether a difference is justified, and what your national law requires on top of the Directive, are questions for your employment lawyer. We cite article numbers so they can check our working.

Does my payroll really never leave my computer?

Yes. The app is static files. Your file is read and analysed in your browser, and the production build ships a Content-Security-Policy with connect-src 'self', so the page cannot open connections to any other server. Open your browser's network panel while you import: you will see no upload.

Why hourly pay rather than annual salary?

Article 3 defines pay level as gross annual pay and the corresponding gross hourly pay. Comparing annual figures would make every part-timer look underpaid. Levelbook converts each worker's pay for the year to an hourly rate using contractual hours or FTE, and months employed for joiners and leavers.

What counts as complementary or variable pay?

Anything beyond the ordinary basic wage or salary, in cash or in kind: bonuses, commissions, allowances, overtime premiums, company car benefit, vouchers. Map each column; Levelbook sums them.

How are categories of workers decided?

You decide, on objective, gender-neutral criteria: skills, effort, responsibility and working conditions at minimum (Article 4(4)), agreed with workers’ representatives where they exist. Levelbook gives you a scoring tool and a suggested grouping, and shows when a category is too small to read reliably.

Our country has not transposed yet. Should we wait?

Not for the data work. The Directive sets 7 June 2027, on 2026 pay, for employers with 150 or more workers. Your national law decides the date that binds you, and a few Member States may start later. Either way, clean data and defensible categories take longest; start there.

What about workers who are neither recorded as female nor male?

They are counted in your headcount and quartile bands. The Directive defines gaps between female and male workers, so they are excluded from the gap arithmetic and the report says so.

We only report every three years. Do we pay every year?

No. Employers with 100 to 249 workers report every three years (Art. 9(2)), so they buy a Single report when it is due. Workers can still ask for pay information at any time (Art. 7), and pay rounds move your gap, so there is an optional €129 a year for letters and checks between reports.

How do I buy a licence?

Fill in the licence request with your company and VAT details. We email the invoice within one working day; pay by bank transfer, card or SEPA debit, and the licence file arrives by email. Import it on the Report or Project page and your reports lose the Draft mark. No account, and the licence is checked on your device.

What happens when early access ends?

Nothing you rely on disappears. Analysis stays free for good, and your projects stay on your computer. From 31 January 2027, founding-customer pricing closes. A clean PDF report without the Draft mark needs a licence, during early access and after it.

Can I use it for more than one company?

Yes. Export each project as a file and open it again later. The Partner plan covers up to 25 employers with white-label reports.

Find your gaps before the report does.

Open the sample company and see a finished analysis in under a minute. Then try it with your own file; it stays with you.