As of June 2026, France has not yet transposed the EU Pay Transparency Directive. However, a draft law published in early June gives employers a clearer view of what implementation may look like.
The draft would amend existing laws, including the Labour Code, and update France’s existing Egapro reporting system, which already applies from 50 employees. That means we’re not looking at a whole new framework, but a more detailed version of the current system with new employer obligations and employee rights.
Below, we break down what is expected to change for French employers and which details are still waiting for future decrees.
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Transposition status in France at a glance
France’s pay transparency law in detail
France’s draft law would update its existing gender equality reporting framework, mainly through changes to the Labour Code for private-sector employers. Reporting would continue to apply from 50 employees. Many technical details still need to be set by decree. Here are the main employer obligations according to the current draft:
Analysis: What France’s law means in practice
France’s draft law is still subject to change, but it already shows where the biggest practical work will be. Here are some of the most important practical challenges for employers operating in France.
French employers don’t need to start from scratch when it comes to pay equity reporting
France’s draft law would adapt the Index de l’égalité professionnelle (Egapro index), which employers with 50 or more employees already report each year. The main change is a new category-level indicator showing the gender pay gap in each group of employees doing the same work or work of equal value. Employers will need to think more carefully about how employees are grouped, which pay data is used and how any gaps can be explained.
The updated Egapro framework will still apply from 50 employees, but employers with 50–249 employees will only include the new category-level indicator every three years. The obligation will also be phased in: no later than three years after promulgation for companies with 100–149 employees, and no later than six years after promulgation for companies with 50–99 employees.
The practical message here is that French employers don’t need to build from zero. Many are already used to collecting pay data, calculating indicators and publishing gender equality results. But, while existing processes are a useful starting point, employers will need to adapt them for more granular, category-level reporting.
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 draft allows categories to be defined through a company agreement or branch agreement. If no agreement is reached, the employer can define them by unilateral decision after informing and consulting the CSE.
For employers, the question is whether existing job families, levels or classifications are precise enough for equal-value comparisons, and whether they can be connected clearly to pay data, reporting and employee requests.
Employers will need a clear process for working with the CSE
The Comité social et économique (CSE — the employee representative body in French companies), will be involved in several parts of the new framework.
Employers with 50–99 employees must inform the CSE about the data, calculation methods and results of the pay gap indicators. Those with 100 or more employees must consult the CSE and send its opinion to the administrative authority as part of the reporting process.
CSEs will also play a role where category-level results are too sensitive to share directly with employees. If disclosure could reveal an individual employee’s pay because the category is too small, the results are transmitted only to the CSE, whose members are subject to confidentiality obligations. In companies with 100 or more employees, CSEs can ask for an explanation of the category-based pay gap, though employers don’t have to respond to requests that are abusive, systematic or repetitive.
Under the new rules, CSEs can also:
- Be consulted on justifications for pay gaps above a threshold
- Be involved in the correction process when a pay gap is unjustified
- Act as an intermediary for employee pay information requests
All of this means pay transparency in France will not simply be a case of preparing and publishing data. Employers will need to be ready to explain the numbers, discuss the methodology and work closely with the CSE.
Technical details remain open, but preparation should start now
The draft law 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
- The methodology for calculating the category-based indicator
- The pay components to be included in calculations
- Detailed penalty calculation and application rules
- The exact rules for categorising employees
- Timelines for responding to employee information requests
Employers should not wait for those decrees before starting preparation. They can already review pay data, define equal-value categories, prepare for employee information requests and plan how to work with the CSE.
That said, employers should avoid building a detailed compliance process around assumptions. One simple example is the pay gap threshold that will trigger corrective action. Many expect it to be 5% (in line with the Directive), but that’s not yet confirmed. Employers will need to keep their processes flexible until final details are confirmed.
Key preparation steps for employers in France
Employers in France can start preparing for the main changes now. Focus on these 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 category-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 in writing.
- 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 draft law is not final, 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.
