2026 Income Reporting In Austria: The Last Cycle Before The EU Pay Transparency Reform?

March 2026 – Employers in Austria with more than 150 employees are facing a significant compliance moment. By 31 March 2026, the next biennial income report under Austria's Equal Treatment Act (Gleichbehandlungsgesetz) becomes due, and importantly, this is very likely the final reporting round under the current national framework.

The reason? Austria is obliged to transpose the EU Pay Transparency Directive (2023/970) by 7 June 2026, triggering far-reaching changes to pay reporting, equal pay assessments, and employee information rights.

What must be reported in 2026?

Under Section 11a of the Austrian Equal Treatment Act, employers with more than 150 permanent employees must prepare a comprehensive income report (Einkommensbericht) every two years. This internal report must include:

• workforce structure by gender and employment group;
• employment group years split by gender;
• average or median remuneration of women and men, adjusted to ensure comparability across part‑time and partial‑year employment.

This is not just a headcount report, it requires clean data, structured methodology, and defensible analytics.

The report is not filed with a regulator or public body. Instead, it must be delivered internally by 31 March 2026:

• to the Central Works Council (Zentralbetriebsrat), if one exists;
• otherwise, to the Works Committees (Betriebsausschüssen);
• if none exist, to any Works Council (Betriebsrat); or
• if no employee representative body exists, the report must be made available in a room accessible to all employees, and its availability must be announced.

Because employees (or employee representative bodies) have a legal right to receive the report, non‑compliance can be litigated. Claims must be brought within three years.

Outlook: New obligations under the EU Pay Transparency Directive

Austria has not yet published a draft transposition law but must implement the EU Pay Transparency Directive by 7 June 2026. The Directive dramatically expands employee rights and employer reporting duties.

Transparency and information obligations

Under the Directive, Employers are required to disclose starting salaries or salary ranges during recruitment, use gender‑neutral job titles and processes, and refrain from asking candidates about past remuneration. Once employed, employees gain the right to request detailed information on their inpidual pay and the average pay of employees in comparable roles. Employers must provide such information promptly, objectively, and in an accessible, GDPR‑compliant format.

Reporting obligations

Beyond inpidual rights, the Directive requires structured gender pay-gap reporting that goes far beyond Austria's current income report. It mandates quartile analysis, variable-pay distribution, and comprehensive pay-gap metrics, with reporting start dates and frequency tied to workforce size and generally applying to companies with at least 100 employees.

Unlike the current report, the new report must not only be delivered internally but must also be submitted to a monitoring body and will be published.

Where pay gaps of 5% or more cannot be justified by objective, gender‑neutral criteria and remain unaddressed for six months, employers must conduct a joint pay assessment with employee representatives.

Practical next steps for employer

These obligations require employers to establish robust data systems, clear job architecture, transparent pay‑setting criteria, and consistent documentation. For most organisations, compliance will require significant preparation, especially in recruitment, HR and payroll alignment, works council engagement, and internal governance around pay‑related decisions.

For these reasons, the 2026 Austrian income report should not be seen as a routine reporting exercise. It is a strategic opportunity for employers to test pay analytics, identify risk areas, and prepare for the far more intrusive EU pay transparency obligations. Early preparation will significantly reduce legal exposure, operational friction, and reputational risks in this new era of pay transparency.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.