As of September 2026, France has not yet transposed the EU Pay Transparency Directive. A revised bill was submitted to the Conseil des Ministres on 10 September, but it still needs to pass through Parliament.
French employers won’t be starting from scratch on pay transparency: France already has a well-established professional equality reporting framework for companies with 50 or more employees. But the new rules would make that framework more detailed, with new employee rights and much more emphasis on how companies group and compare work of equal value.
Here’s what HR and compensation teams need to know about the current bill and where the details are still taking shape.
Transposition status in France at a glance
France’s pay transparency law in detail
France’s bill will update its existing gender equality reporting framework, mainly through changes to the Labour Code for private-sector employers. Reporting will continue to apply from 50 employees, although some obligations will follow different implementation timelines depending on employer size. Many technical details still need to be set by decree. Here are the main employer obligations according to the current bill:
Analysis: What France’s law means in practice
The bill could still change as it moves through Parliament, but the main preparation challenges are becoming much clearer. For French employers, the biggest question is whether their existing reporting, job structures and employee-representation processes are ready for a more detailed level of transparency. Here are the main practical implications of the bill as we understand it so far.
French employers don’t need to start from scratch when it comes to pay equity reporting
France’s existing reporting system gives employers a useful head start. Companies with 50 or more employees are already used to collecting pay data, calculating indicators and publishing gender-equality results.
But the new framework requires employers to go further. In particular, employers will need to connect reporting to categories of employees doing the same work or work of equal value. That puts much more pressure on how roles are classified, how pay data is structured and whether employers can explain the differences the numbers reveal.
The category-level indicator also follows a later phase-in for smaller employers, while the other reporting indicators stay on the general implementation timetable.
Equal-value categories are the main preparation challenge
One of the biggest preparation tasks is defining categories of employees doing the same work or work of equal value. These categories feed into different parts of the law, including the new pay gap indicator, employee information rights and corrective action for unjustified gaps.
The bill puts responsibility for this categorisation at company level, with different roles for the employer, the CSE and industry-level agreements:
- Company agreement: Employers will first try to agree the categories at company level.
- Employer decision: If no agreement is reached, the employer can define the categories itself after consulting the Comité social et économique (CSE — the employee representative body in French companies).
- Industry-level agreement: A sector-wide collective agreement can provide a methodology or framework for categorisation, but it will not set the categories for individual companies.
In practice, that means employers can’t simply rely on a sector-wide classification and assume the work is done. They will need to be able to explain how their own categories were created, which criteria were used and why particular roles have been grouped together.
Employers will need a clear process for working with the CSE
The CSE will be involved at several points in the pay transparency process.
Employers with 50–99 employees must inform the CSE about the data, calculation methods and results of the pay gap indicators. From 100 employees, employers must formally consult the CSE on the reporting and submit its opinion to the authorities.
The CSE can also receive sensitive pay information where sharing it directly with an employee could reveal another person’s salary.
For employers with 100+ employees, the CSE can also:
- Ask for explanations of reported pay gap indicators
- Be consulted on the reasons for significant pay gaps
- Be involved in measures to correct unjustified gaps
In practice, employers will need to build CSE involvement into the process rather than treating it as a final sign-off step.
Technical details remain open, but preparation should start now
The bill shows the broad shape of France’s future pay transparency rules, but many practical details have been left to future decrees. For example, the following are still missing:
- The pay gap threshold that triggers corrective action
- Detailed calculation methods and pay elements for the reporting indicators
- The objective criteria that can justify pay gaps
- The minimum threshold used to protect confidentiality
- Rules for calculating employer headcount
- Some detailed implementation dates and procedures
That uncertainty doesn’t mean employers need to sit on their hands. There is plenty they can work on without knowing every calculation rule: cleaning up pay data, reviewing job classifications, working out how employee requests will be handled and planning CSE involvement.
That said, employers should avoid building a detailed compliance process around assumptions. The pay gap threshold that will trigger corrective action is a good example: the bill confirms that there will be a threshold, but the figure itself will be set by decree. Employers will need to keep their processes flexible until those details are confirmed.
Key preparation steps for employers in France
Employers in France can start preparing for the main changes now. Focus on theFrench employers don’t need every decree in place before they start preparing. These are the areas worth prioritising now:se steps first:
- Separate what can move forward now from what depends on future decrees.
- Compare your current Egapro reporting process with the draft’s new requirements, especially the categCompare your current Egapro reporting process with the bill’s new requirements, especially the category-level pay gap indicator and its different implementation timelines.ory-level pay gap indicator.
- Start defining equal-value categories using objective criteria such as skills, responsibilities, working conditions and physical or mental load.
- Align internal roles, job levels and salary bands with the categories used for reporting and employee information rights.
- Update job adverts to include the proposed pay range and relevant collective agreement provisions.
- Remove any process steps that ask candidates about current or previous pay.
- Review contracts and policies to remove pay confidentiality clauses.
- Create a process for informing employees annually of their pay information rights and responding to requests within two months.
- Prepare to inform and consult the CSE on indicator data, calculation methods, results, explanations and corrective measures.
Learn more about the Pay Transparency Directive
France’s bill has not yet been adopted, but the direction is clear: pay transparency will mean more than publishing numbers. Employers will need to define meaningful equal-value categories, prepare cleaner pay data and be ready to explain where pay gaps come from.
For the broader EU context, read our full guide to EU Pay Transparency Directive implementation to see how the rules are taking shape across Europe.
