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

The Directive applies broadly - not just to full-time staff, but to almost anyone with an employment relationship. This includes:

• Full-time and part-time workers
• Temporary and agency staff
• Platform workers (such as gig economy roles)
• Fixed-term or on-call workers

Depending on national law, it may also include apprentices or domestic workers. Freelancers and self-employed individuals are generally excluded — unless reclassified under local labour rules.
 

The EU Pay Transparency Directive was designed to cover a wide and inclusive definition of “worker”, making sure transparency isn’t limited to traditional full-time roles.

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

Potentially included:

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

Typically excluded:

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

Because the Directive leaves scope definitions to national governments, exact coverage may vary across countries. That means it’s important to monitor how your local legislation is evolving.
 

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.
   

Pay transparency applies to far more than just your core workforce. By understanding who’s included (and preparing for possible expansions under national law), you’ll ensure your reporting is accurate, credible, and fair.