Which employees are included in the scope of the Pay Transparency Directive?

The EU Pay Transparency Directive takes a broad view of who counts as a “worker.” It goes beyond traditional full-time staff, covering most people with an employment relationship. The aim is to make sure pay reporting reflects the reality of today’s diverse workforce.

Here’s how that looks in practice in Europe: 

Covered roles include: 

• Full-time and part-time employees
• Fixed-term and permanent staff
• Temporary agency workers
• Platform/gig economy workers
• On-call, intermittent, or zero-hours workers 

In Ireland, changes might be present. For example, platform and gig economy workers in Ireland are not automatically included unless their role is reclassified as employment under national law. 

Potentially included: 

• Apprentices and trainees
• Domestic workers (depending on national interpretation) 

Apprentices and trainees may be included depending on how Ireland defines ‘worker’ under its transposition of the Directive, with the same true of domestic workers. 

Typically excluded: 

• Freelancers and the self-employed - unless national rules reclassify their roles due to dependency or employer-style control. 

Employees in a particular sector (such as construction or security), and workers who are represented by a trade union, sometimes have their working conditions set out in a particular employment agreement or employment order. These may influence how certain roles are treated under pay transparency rules. 

​Final scope is set by each EU country, so coverage can vary. Keep an eye on how your local rules evolve. For employers, that means keeping track of national changes while preparing reports that reflect your full workforce fairly. 

When you prepare pay reports, you’ll need to calculate averages, gaps, and distributions across different groups of workers. If certain contract types are excluded or misclassified, that could distort your figures, or expose you to compliance risk. 

 To prepare: 

• Review your workforce breakdown by contract type.
• Track how your country defines scope and obligations.
• Consider whether “non-standard” workers should be included in your reporting, even if not explicitly required. The broader and more inclusive your understanding of scope, the more accurate and credible your reporting will be. 

 See also: What is a “category of workers,” and how should we define it for reporting?

Pay transparency covers more than your core workforce. By knowing who’s in scope, and planning for possible national changes, your reporting stays accurate, credible and fair.