Pay Transparency Implementation Country by country

This page provides country-specific updates on how pay equity regulations are being drafted and implemented. It offers clear, up-to-date insights to help organizations understand local requirements and prepare for upcoming changes.

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Poland’s Draft Equal Pay Act

What employers need to know before June 2026

The draft Act on strengthening the right to equal pay introduces clear and enforceable obligations for employers. While equal pay is already a legal principle, this proposal focuses on how employers must prove compliance in practice through job evaluation, pay transparency, reporting, and corrective action.

Below is an easy overview of the most important points for employers.

Pay transparency in recruitment
Employers will be required to provide information on the starting salary or salary range in job advertisements or before the recruitment process begins. Asking candidates about their pay history will be prohibited.

Job evaluation and equal work
Employers must be able to demonstrate that pay differences are based on objective, gender-neutral criteria. This places greater emphasis on structured job evaluation, clear role definitions, and documented pay-setting processes.

Employee right to pay information
Employees will gain the right to request information about their own pay level and the average pay for comparable roles, broken down by gender. Employers must respond within defined time limits.

Pay gap reporting
Larger employers will be subject to regular gender pay gap reporting obligations. Where unjustified pay gaps are identified, employers may be required to carry out joint pay assessments and implement corrective measures.

Enforcement and sanctions
The draft law introduces clearer enforcement mechanisms, including potential fines and compensation claims. The burden of proof will shift more strongly to employers in equal pay disputes.

Timeline and preparation
The Act is expected to enter into force ahead of the EU deadline in June 2026. Employers should begin reviewing pay structures, job architecture, and data availability well in advance to reduce compliance and litigation risk.

Overall, the Polish implementation signals a shift from principle to proof—requiring employers to actively demonstrate that pay decisions are fair, transparent, and gender-neutral.

Lithuania implements the directive

What employers need to know before June 2026

Lithuania has published draft legislation to transpose the EU Pay Transparency Directive, primarily through amendments to the Labour Code and related enforcement rules (including the Administrative Offences framework). The draft builds on existing Lithuanian transparency requirements and adds clearer, enforceable obligations around recruitment transparency, pay-setting rules, employee information rights, and (for larger employers) pay gap reporting and follow-up action.

Below is an easy overview of the most important points for employers.

Pay transparency in recruitment
Employers will need to provide pay information to applicants, and the draft goes beyond the Directive by requiring salary ranges to be included directly in job advertisements.

Ban on salary history questions
Employers will be prohibited from asking candidates about their previous pay (salary history), aligning with the Directive’s approach to reducing bias in pay-setting.

Transparent pay-setting and pay progression criteria
Employers will be expected to make pay-setting and pay progression criteria accessible to workers and ensure these criteria are objective and gender-neutral in practice (i.e., documented and explainable).

Employee right to pay information
Workers will gain an explicit right to request information, including their own pay level and average pay levels for categories of workers performing the same work or work of equal value (typically with gender breakdown requirements). Employers must be able to respond using reliable HR/pay data.

Pay gap reporting and follow-up action
Lithuania already has some reporting-related obligations, and the draft is intended to complete alignment with the Directive’s reporting and remediation model for larger employers (including steps to address unexplained pay gaps).

Enforcement and penalties
The draft includes enforceable sanctions for non-compliance; published summaries cite administrative penalties in the range of approximately EUR 400 to EUR 6,000 (depending on the breach).

Timeline and preparation
The EU transposition deadline is 7 June 2026, and employers should prepare early by tightening job architecture, defining pay-setting rules, and ensuring they can produce the required pay data quickly and consistently.

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Germany’s “Pay Transparency Act 2.0” (expected)

What employers need to know before June 2026

Germany is preparing to transpose the EU Pay Transparency Directive by 7 June 2026, primarily by amending the existing Pay Transparency Act (Entgelttransparenzgesetz, EntgTranspG). As of January 2026, implementation work has been driven by an expert commission (final proposals delivered 7 November 2025) and a federal legislative process planned to start in early 2026.

Germany is preparing to transpose the EU Pay Transparency Directive by 7 June 2026, primarily by amending the existing Pay Transparency Act (Entgelttransparenzgesetz, EntgTranspG). As of January 2026, implementation work has been driven by an expert commission (final proposals delivered 7 November 2025) and a federal legislative process planned to start in early 2026.

Below is an easy overview of the most important points for employers.

Pay transparency in recruitment
Employers will need to inform applicants about the starting pay or pay range (based on objective, gender-neutral criteria) and relevant collective agreement provisions—typically in the job ad, before interview, or otherwise early in the process. Asking candidates about pay history will be prohibited.

Transparent pay-setting and pay progression criteria
Employers will be expected to define and make accessible the objective, gender-neutral criteria used for pay, pay levels, and pay development (pay progression). This increases the need for structured job architecture and documented pay governance.

Employee right to pay information
Employees will have a strengthened right to request written information about their individual pay and average pay for comparable work, broken down by gender. Guidance indicates this entitlement may need to be actively communicated to employees (e.g., annually).

Pay gap reporting (scope and data approach)
Reporting is expected to follow the Directive’s model, and German discussions focus on practical reporting design, including basing reporting on actual remuneration, defining “median/average” clearly, using full-time equivalents, and enabling group reporting in corporate groups.
Commission recommendations also point toward limiting the initial reporting obligation to employers with 100+ employees and providing digital templates/tools to reduce administrative burden.

Corrective action if unexplained gaps persist
Where a pay gap (commonly referenced as >5%) cannot be objectively justified and is not corrected within the required timeframe, employers will face a duty to take remedial steps—potentially via a staged process involving employee representatives and a time-bound roadmap for fixes.

Enforcement and litigation risk
Employers should expect stronger enforcement, including broader access to compensation and procedural tools that can increase claims (including representative actions).
Commission proposals also discuss how reporting outcomes (e.g., a gap below a defined threshold) could interact with burdens of proof in disputes.

Timeline and preparation
The deadline remains 7 June 2026. With a legislative process expected to accelerate in 2026, employers should prioritize: role/job evaluation readiness, pay-setting documentation, HRIS/payroll reporting capability, and an action plan for gap remediation.

Sweden’s Draft Pay Transparency Implementation

Sweden was among the first EU Member States to publish a formal proposal on how it plans to transpose the EU pay transparency directive into national law. The government’s Inquiry Report (SOU 2024:40) sets out amendments to the Discrimination Act (Diskrimineringslagen) to meet the Directive’s requirements, building on Sweden’s existing pay equity framework and annual pay surveys.

Pay transparency in recruitment
Employers will need to provide job applicants with information on the starting salary or salary range for a position and any relevant collective agreement provisions in good time before salary negotiations. The draft also prohibits asking applicants about their pay history.

Objective, gender-neutral pay setting and internal transparency
Sweden’s proposal would require employers to make accessible the objective, gender-neutral criteria used to determine pay levels and pay progression. This goes beyond existing statutory equal pay surveys by embedding transparency obligations directly into law.

Employee right to pay information
Employees will gain expanded rights to receive information on their own pay and the average pay for comparable roles, broken down by gender. This aligns with the Directive and strengthens existing transparency mechanisms under Swedish equality law.

Gender pay gap reporting
Employers with 100 or more employees will be obliged to report gender pay gap data to the Equality Ombudsman (Diskrimineringsombudsmannen, DO). Reports must explain pay differences of a defined size with objective reasons or corrective actions. The DO may publish overall statistics.

Corrective measures
If pay gaps of 5 % or more between men and women performing equal or equivalent work cannot be objectively justified, employers will need to take remedial action or further analyse the causes in consultation with employee representatives.

Enforcement and sanctions
The legislative proposal reinforces the role of the Equality Ombudsman in supervising compliance. Non-compliance with reporting and information duties may lead to sanctions or damages, and the burden of proof may shift to employers in disputes.

Timeline and preparation
The inquiry’s report was published in May 2024 and is under government review; the formal government bill was expected in January 2026 with adoption to follow. Legislation is planned to take effect by June 2026, though some stakeholder groups are urging a possible later implementation date to allow adequate preparation.

Overall, Sweden’s approach embeds the Directive’s requirements in the existing equality framework, maintains robust pay audit practices, and adds explicit transparency and reporting duties to strengthen equal pay enforcement.

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Belgium’s Pay Transparency Implementation

Belgium does not yet have national legislation fully transposing the EU pay transparency directive (Directive (EU) 2023/970) for all employers, but there has been notable early implementation at the regional level and active preparatory work involving social partners and legislators.

Early regional transposition – Wallonia-Brussels Federation
The Fédération Wallonie-Bruxelles (French-speaking Community of Belgium) became the first jurisdiction in the EU to transpose the Directive in part via a regional decree that entered into force on 1 January 2025. This applies to public-sector bodies and institutions under that region’s competence and incorporates key transparency requirements such as pay range disclosure and prohibition of pay history questions.

Status of national implementation
At the federal level, Belgium has not yet adopted full transposition legislation. Social partners (employer and employee organisations) and the competent ministry are working on amendments to existing frameworks, including Collective Bargaining Agreement (CBA) No. 25 (equal pay) and CBA No. 38 (recruitment and selection), and potential new national law proposals — but issues remain unresolved as of late 2025 and formal transposition for all employers is still pending.

Existing national equal pay framework
Belgium already has laws on equal pay for equal work, and employers with 50+ employees must produce gender pay gap reports under the 2012 pay gap legislation. These existing obligations provide a starting point for compliance, but they generally lack the transparency and employee information rights required by the Directive.

Pay transparency in recruitment and pay information
Once transposed nationally, employers will be required to:

  • Provide starting salary or pay range information to job applicants in advance of recruitment stages;

  • Prohibit asking job applicants about pay history during recruitment;

  • Make pay criteria and pay progression principles accessible to workers;

  • Respond to employee requests for pay information (e.g., own pay and average pay for comparable roles).

Pay gap reporting and corrective action
The Directive’s reporting and joint pay assessment obligations (for employers above certain size thresholds) will need to be integrated into Belgian law. Employers should expect expanded reporting requirements beyond the current pay gap analysis and potentially corrective action duties where unjustified gaps are identified.

Enforcement and preparation
Belgian employers should begin preparing by:

  • Reviewing pay structures and job evaluation systems;

  • Mapping roles and pay data for future reporting;

  • Ensuring recruitment processes avoid prohibited pay history questions;

  • Engaging with employee representatives on transparency plans.

Timeline
The EU transposition deadline is 7 June 2026. Although partial implementation exists in one region, nationwide federal transposition remains in progress and employers should closely monitor developments to ensure compliance by the deadline.

Belgium’s early regional implementation in Wallonia-Brussels provides a preview of how pay transparency rules will operate, but a comprehensive national framework — including recruitment pay transparency, employee information rights, reporting, and enforcement — is still expected to be finalised in 2026.

Ireland’s Draft Pay Transparency Implementation

Ireland is actively preparing to transpose the EU pay transparency directive into national law ahead of the 7 June 2026 deadline. On 15 January 2025, the Government published the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024, which includes draft provisions to implement key transparency measures — making Ireland one of the earlier Member States to publish formal draft legislation in respect of the Directive.

Below is an easy overview of the most important points for employers.

Pay transparency in recruitment
The draft Bill would require that employers include the salary level or pay range in job advertisements, going slightly further than the Directive’s minimum requirement (which allows employers to provide this information any time before a job offer).
It also proposes a ban on asking applicants about their pay history (current or past salaries), aligning with the Directive’s aims to reduce bias in pay-setting.

Employee right to pay information
Under the Directive, employees will have the right to request information about their own pay and the average pay for categories of workers doing the same work or work of equal value, by gender. Ireland’s draft touches on transparency but additional legislative steps are expected to fully implement these information rights.

Gender pay gap reporting and corrective action
Ireland already has gender pay gap reporting in place under the Gender Pay Gap Information Act 2021 (applying to employers with 50+ employees). The Directive will expand these requirements by:

  • Requiring reporting by categories of workers (not just overall figures), and

  • Introducing joint pay assessments and corrective action where unexplained gaps of 5 % or more are found.

Transparent pay-setting and bans on secrecy
The Directive also prohibits pay secrecy clauses in contracts and requires employers to document and communicate objective, gender-neutral criteria for pay and progression — changes Ireland will need to reflect in its implementing legislation.

Enforcement and burden of proof
Once transposed, Ireland’s law is expected to shift the burden of proof in pay discrimination cases toward employers and strengthen enforcement mechanisms, including meaningful remedies and penalties for non-compliance.

Timeline and preparation
The draft Bill is still progressing through the legislative process, and its final form may change. Full transposition will require additional amendments beyond the draft — particularly on employee pay information, reporting, and corrective duties — to align with the Directive’s scope. Employers should prepare by reviewing recruitment practices, pay structures, and reporting systems well before June 2026.

Overall, Ireland’s approach combines draft statutory measures with enhancements to existing gender pay gap reporting, moving toward a broader pay transparency framework in compliance with EU law.

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The Netherlands’ Draft Pay Transparency Act

What employers need to know before June 2026

The Netherlands has published a draft bill to implement the EU Pay Transparency Directive (Directive (EU) 2023/970) by amending key national employment laws, including the Equal Treatment of Men and Women Act and related statutes. The draft aims to transpose the Directive’s requirements into Dutch law through a “pure implementation”—largely mirroring the Directive’s text and minimum obligations.

Below is an easy overview of the most important points for employers.

Pay transparency in recruitment
Employers will be required to provide salary information (starting pay or pay range) to job applicants early in the recruitment process, typically in job postings or before interviews. Employers will also be prohibited from asking candidates about their pay history. All employers, regardless of size, will need to comply with these obligations once the law is in force.

Objective and gender-neutral pay setting
Employers must establish transparent pay structures based on objective, gender-neutral criteria (e.g., skills, responsibilities, effort, working conditions) that ensure equal pay for equal or equivalent work. These criteria and structures will need to be documented and accessible to employees, particularly for employers with employee representative bodies.

Employee right to pay information
Employees will be entitled to request information about their own pay and the pay of comparable workers (including basic and variable pay components), often broken down by gender. Employers may have specific timeframes to respond to such requests.

Pay gap reporting and corrective action
Under the draft law:

  • Employers with 100 employees or more are expected to have a pay gap reporting obligation.

  • Reporting is likely to be phased: for example, first reports from larger employers (with 150+ employees) may relate to 2027 data (due in 2028) due to delays in implementation.

  • Reports should include gender pay gaps across categories of workers and pay components, and employers will need to address unexplained gaps and involve works councils in remediation planning.

Works councils and employee representatives
Dutch implementation assigns an active role to works councils (e.g., in reviewing pay structures and agreeing on corrective measures), especially for larger employers. Preparatory steps with employee representatives will be essential for meeting consultation and reporting duties.

Timeline and implementation status

  • The draft bill was published on 26 March 2025 and underwent public consultation until 7 May 2025.

  • Formal adoption and entry into force are in progress, with the government planning for implementation by 1 January 2027—after the EU deadline of 7 June 2026.

  • The European Commission has rejected requests to delay the Netherlands’ implementation beyond June 2026, meaning employers should prepare based on Directive obligations even if national legislation is not yet final.

Employers operating in the Netherlands should begin preparing now by reviewing pay structures, documenting pay criteria, engaging works councils, and ensuring systems can produce the pay data needed for reporting and employee information rights.

Finland’s Draft Pay Transparency Reform

What employers need to know before June 2026

Finland is preparing amendments to the Act on Equality between Women and Men and related legislation to implement the EU Pay Transparency Directive by the 7 June 2026 deadline. Finland already has comparatively advanced gender pay and equality obligations, but the reform significantly strengthens transparency, documentation, and employee rights, and introduces new employer duties in recruitment and pay reporting.

Below is an easy overview of the most important points for employers.

Pay transparency in recruitment

Employers will be required to inform job applicants about the starting salary or salary range for a position. This information must be provided in a clear and timely manner, typically already in the job advertisement or before the recruitment process progresses. Asking candidates about their pay history will be prohibited.

Objective and gender-neutral pay-setting

Employers must ensure that pay-setting and pay progression are based on objective, gender-neutral criteria. While this principle already exists in Finnish law, the draft reform increases expectations around documentation, consistency, and the employer’s ability to demonstrate how pay decisions are made in practice.

Employee right to pay information

Employees will gain an expanded right to request information about their own pay level and the average pay levels for comparable work or work of equal value, broken down by gender. Employers will be required to respond within statutory time limits.

Pay gap reporting and equality plans

Finland already requires employers with at least 30 employees to prepare equality plans that include pay surveys. The draft implementation aligns these existing obligations with the Directive by strengthening the methodology, standardising reporting, and introducing clearer follow-up duties where unjustified pay gaps are identified.

Corrective measures and joint assessments

Where a gender pay gap cannot be objectively justified, employers may be required to carry out a joint pay assessment together with employee representatives and implement corrective measures within a defined timeframe.

Enforcement and sanctions

The reform strengthens enforcement by the Equality Ombudsman and other supervisory authorities. Employers may face administrative sanctions and increased litigation risk if they fail to meet transparency or corrective obligations.

Timeline and preparation

The amended rules are expected to enter into force by June 2026. Employers should begin preparing by reviewing job evaluation frameworks, updating equality plans and pay surveys, and ensuring HR and payroll systems can support the new transparency and reporting requirements.

Overall, Finland’s approach builds on an already mature equality framework but raises the bar on proof, transparency, and follow-through—requiring employers not just to promote equal pay, but to clearly demonstrate it.

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Malta’s Draft Pay Transparency Implementation

What employers need to know before June 2026

Malta has begun transposing the EU Pay Transparency Directive (Directive (EU) 2023/970) into national law with the publication of Legal Notice 112 of 2025 (amending the Transparent and Predictable Working Conditions Regulations under the Employment and Industrial Relations Act). This represents Malta’s first formal step toward full implementation by the 7 June 2026 deadline.

Below is an easy overview of the most important points for employers.

Pay transparency in recruitment
From 27 August 2025, employers must provide job applicants with the initial pay or pay range for the position before employment starts. Where a relevant collective agreement applies, employers must also share the applicable pay provisions.
Current rules do not yet require mandatory inclusion of pay ranges in all job advertisements, but the intent of full Directive transposition will align Maltese law with the requirement to share this information early in the recruitment process.

Employee right to pay information
During employment, employees have the right to request, in writing, information about their individual pay level as well as the pay levels for colleagues performing the same work. Employers must respond within a “reasonable period” — defined in practice as no later than two months from the request.
These rights currently focus on “same work” rather than the broader work of equal value concept in the Directive, and may be expanded in further legislation.

Ban on pay history questions and job ads (to be fully implemented)
The EU Directive prohibits employers from asking applicants about past pay and requires salary disclosure before interviews. Malta’s Legal Notice does not yet explicitly adopt these provisions, but future transposition steps are expected to align national law with the Directive.

Pay gap reporting and corrective action (forthcoming)
Malta currently has no standalone gender pay gap reporting law. Full transposition will require introducing obligations for employers (with thresholds based on size) to report pay gap metrics and, where unexplained gaps occur, to carry out joint pay assessments and corrective actions under the Directive’s framework.

Enforcement and timeline
Legal Notice 112 has already entered into force, giving job applicants and employees new rights on pay information. Employers should prepare for additional implementing legislation by June 2026, which will complete full Directive requirements, including transparency on pay criteria, reporting, and remediation duties.

Preparation for employers
Employers in Malta should:

  • Begin disclosing pay ranges and related collective agreement terms to applicants.

  • Update internal pay documentation and request processes.

  • Audit pay structures and systems ahead of reporting and corrective duties later in 2026.

Overall, Malta’s implementation starts with basic transparency rights and is expected to be expanded to cover the full suite of pay transparency, reporting, and corrective provisions under the Directive by the transposition deadline.

Slovakia’s Draft Pay Transparency Act

Slovakia has published draft legislation to transpose the EU Pay Transparency Directive into national law. The draft “Law on Equal Pay for Men and Women for Equal Work or Work of Equal Value” and related amendments are intended to fully implement the Directive in Slovak labour law, replacing partial transparency measures with a comprehensive statutory framework. The draft was published on 19 September 2025 and is currently progressing through public consultation and the legislative process. If adopted, the law is expected to take effect on 1 June 2026 ahead of the EU deadline.

 

Pay transparency in recruitment
Employers must provide job applicants with information on the initial pay level or pay range either in job postings or before a job interview. Job advertisements must be presented in gender-neutral language, and employers are prohibited from asking candidates about their current or past pay.

Objective and gender-neutral pay structures
Employers will be required to establish formal pay structures based on objective, gender-neutral criteria (such as skills, responsibilities, effort, and working conditions). These criteria must be documented and accessible so that pay decisions can be justified and audited.

Employee right to pay information
Employees will have the right to request information about their own pay level and average pay for categories of workers doing the same work or work of equal value, broken down by gender. Employers must respond to such requests, typically within mandated timeframes (often within two months).

Gender pay gap reporting
The draft law introduces pay gap reporting obligations for larger employers:

  • 250+ employees: annual reporting;

  • 100–249 employees: reporting every three years (with initial reporting deadlines phased based on size).
    Reports must cover standard metrics required by the Directive, including pay gaps in basic and variable pay, and gender representation across pay bands.

Joint pay assessments and corrective action
If a gender pay gap of 5 % or more in any worker category cannot be justified by objective criteria, employers must conduct a joint pay assessment with employee representatives and adopt an action plan to address the gap within a defined timeframe.

Enforcement and sanctions
The draft shifts the burden of proof toward employers in discrimination claims: once an employee shows facts suggesting unequal pay, the employer must demonstrate they acted objectively. Employers who fail to comply with reporting duties may face fines (e.g., up to EUR 4 000), and other breaches can trigger higher administrative penalties.

Timeline and preparation
The draft law is expected to take effect on 1 June 2026, aligning with the Directive’s transposition deadline. Reporting obligations will be phased, with initial reports due in 2027 for the largest employers. Employers should begin preparing now by reviewing job descriptions, pay structures, pay data systems, and internal processes to ensure compliance.

Overall, Slovakia’s draft follows the EU Pay Transparency Directive closely, creating clear transparency, reporting, and corrective obligations that significantly expand employer duties beyond traditional equal pay principles.

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