In May 2025, the French Minister of Labor announced a complete overhaul of the existing Gender Equality Index planned for 2027, with the aim of aligning it with the requirements of the EU Pay Transparency Directive. 

Introduced in 2019, the Index currently applies to companies with at least 50 employees and measures gender pay gaps based on four to five indicators: 

• the gender pay gap;
• the gap in annual pay increases;  
• the gap in promotions; 
• pay increases applied upon return from maternity leave; and
• the proportion of women among the ten highest salaries in the company. 

The new index will be based on seven different indicators (in line with the EU Pay Transparency Directive), which are: 

1. The gender pay gap between women and men;
2. The gender pay gap between women and men in terms of variable and supplementary components;
3. The median gender pay gap between women and men;
4. The median gender pay gap between women and men for variable and supplementary components;
5. The proportion of women and men benefiting from variable and supplementary components;
6. The proportion of women and men in each pay quartile, divided into four equal groups where workers are sorted based on their pay level;
7. The gender pay gap between women and men by category of workers, broken down by ordinary salary or wages and by components.

The Minister clarified that the reporting of the first six indicators will be automated through the DSN (“Déclaration Sociale Nominative” which means Nominative Social Declaration) to lessen the administrative burden on companies. As for the seventh indicator, which cannot be automated, its reporting frequency will be reduced for companies with fewer than 250 employees. These companies will be able to report it just once every three years, unlike those with 250 employees or more who must report it annually. Again, this aligns with the thresholds in the Directive.

To meet the transposition deadline of 7 June, 2026, the Government maintains its ambition to vote on the law by the end of 2025 at the latest.

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At Deloitte, we understand that navigating the demands and complexities of pay equity and transparency can be daunting. Our proposition is designed to help you overcome this challenge and achieve your goals. Our aim is to enable you to pay employees equitably and help you demonstrate that you are doing so.

With our deep multi-disciplinary expertise in reward, employment law, technology & analytics, and behaviour change, we are well-placed to be your trusted partner on this journey. Get in touch to discuss your challenges and needs.

Kathryn Dooks, Partner, Deloitte Legal, 020 7303 2894

Deepinder Lamba, Partner, Deloitte Global Employer Services, 020 7007 2689