France Moves to Reform Gender Equality Index by 2027: What Companies Need to Know

The French government has confirmed a complete overhaul of the Gender Equality Index to comply with European Directive 2023/970 on pay transparency, which will be implemented in full by 2027. The introduction of seven new indicators and stricter HR obligations will likely impact workforce strategy, and companies should begin preparing now.

The proposals are at a preliminary stage, with relatively little detail currently available. Below are the key points for companies to bear in mind, based on the French government’s recent update.

MAKING WAY FOR A MORE STRINGENT EUROPEAN SYSTEM

The current index, which as been in place since 2019, is based on five indicators relating to pay gaps, pay rises, promotions, returning from maternity leave, and the representation of women among the 10 highest-paid employees. While this system has led to measurable progress (an average score of 88.5/100 in 2025), pay gaps persist.

From 2027, a new index will replace the current system entirely. This new index will be based on seven indicators defined in Article 9 of European Directive 2023/970, which are considered to be more accurate and demanding.

THE SEVEN INDICATORS OF THE FUTURE INDEX

The seven indicators of the future Gender Equality Index are as follows:

1. Overall gender pay gap (fixed and variable)
2. Gap in individual pay increases
3. Gap in promotions (mandatory for companies with more than 250 employees)
4. Pay gap upon return from maternity leave
5. Gender parity among the 10 highest-paid employees
6. Gender distribution by pay quartile
7. Pay gaps for jobs of equal value (last indicator cannot be automated)

The first six will be automated via the French payroll declaration system, the Déclaration Sociale Nominative (DSN), while the seventh indicator will have to be reported manually each year (or every three years for companies with 50–250 employees, starting in 2030).

PROVISIONAL TIMETABLE

The provisional timetable is as follows:

• May 21, 2025: The start of a consultation cycle between the Ministry of Labor and social partners
• June 7, 2026: The deadline for transposing the directive into French law
• March 2027: The first declaration according to the new procedures (publication maintained around March 8, International Women's Day)

STRENGTHENED OBLIGATIONS AND PENALTY SYSTEM

Companies will have to correct or justify any pay gap of more than 5%. If they cannot justify it, administrative fines may be imposed.

Other measures imposed by the directive, like the following, will also have a direct impact on HR practices:

• A mandatory disclosure of a salary range in job offers
• Recruiters will be prohibited from asking candidates about their previous salary
• Employees will have the right to access the average remuneration associated with their position

HOW COMPANIES CAN PREPARE NOW

Companies are encouraged to not wait until 2027 to prepare. Complying with this reform involves the following steps:

• An audit of current salary practices
• Updating recruitment procedures
• The gradual integration of new indicators into HR tools
• Consulting with employee representatives in advance

Our team is closely following this issue and will provide more updates as new texts or regulatory details relating to this reform are published.