There are two timelines because the European Directive makes a distinction based on company size. Employers with 150 workers or more are expected to report earlier than employers with 100 to 149 workers. Both groups therefore have a different moment by which the first report must be submitted, and subsequently a different frequency as well.
The distinction is therefore not about whether you must report, but when you do so for the first time and how often thereafter. Employers below one hundred workers fall outside the reporting obligation itself, although other obligations from the Directive apply without a threshold. What exactly applies to your number of workers also depends on how the Directive has been transposed into national legislation in your country.
Why the Directive operates with two timelines
The thinking behind the distinction is that larger organizations typically already have more systems and data to compare pay, and that smaller organizations get more time to arrange job classification and pay policy before figures have to be made public. The Directive therefore links the reporting obligation to two thresholds: 150 workers and 100 workers. Employers with between one hundred and one hundred fifty workers thus get more preparation time than employers who are well above that.
The first timeline: 150 workers or more
Employers with 150 workers or more are, according to the Directive, expected to report first, and then periodically. For this group, the lead-in period is the shortest: job classification, pay policy and underlying data must be arranged earlier because the first reporting deadline is closer. For employers who already fall under existing annual reporting requirements, this often aligns with a cycle that already exists, only with a new component added to it.
The second timeline: 100 to 149 workers
Employers with 100 to 149 workers are, according to the Directive, given more time before the first report must be submitted, and report less frequently thereafter than the larger group. That difference in frequency is for these employers just as relevant as the difference in start date: it determines how often job classification and underlying pay data must be recalculated.
What this means in practice
The practical consequence of two timelines is that your current workforce does not automatically determine when it is your turn, and that the exact date and frequency depend on how the Directive has been transposed into national legislation in your country. If your organization is growing towards one hundred or one hundred fifty workers, it is useful to know now which timeline you will fall under, rather than finding that out only when the first reporting deadline is already approaching. Incidentally, the calculation module that works out the pay gap per category is only relevant for employers who have already reached the threshold of one hundred workers; what the calculation module means for your situation you can read in the overview of the paid services.
Whether and when the reporting obligation applies to your organization can be determined with a few questions. In a few questions you will see which timeline suits youwithout needing an account for that. For the underlying text and the exact wording of the Directive, you can consult the source that has been selected for each topic in the knowledge base per situation. If you are still uncertain about how this relates to other obligations that already apply without a threshold, then the overview of frequently asked questions provides a first indication for that.
This page describes the directive as adopted; the exact date and frequency applicable to your organisation shall be determined by the national law transposing the directive. For an assessment of your specific situation, the competent supervisory authority or a lawyer is the appropriate point of contact. If you would first like an indication yourself, take the free quick-scan or browse through the topics in the knowledge base.