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.
Austria
Austria has not yet published a final draft law implementing the EU Pay Transparency Directive, but significant changes to existing equal pay and reporting obligations are expected before the June 2026 deadline. Austria already requires minimum salary disclosure in job advertisements and income reporting for larger employers, but the Directive will substantially expand these obligations.
Below is an overview of the most important expected changes for employers:
Key Points of Austrian Implementation
Pay transparency in recruitment
Employers are expected to provide clearer salary information during recruitment, including salary ranges or starting salaries. A ban on asking candidates about their salary history is also expected.
Job evaluation and equal work
Employers will need to demonstrate that pay differences are based on objective, gender-neutral criteria. This will increase the importance of structured job architecture, documented pay-setting processes, and consistent role evaluation based on work of equal value.
Employee right to pay information
Employees are expected to gain the right to request information about average pay levels for comparable roles, as well as the criteria used for salary progression and pay decisions.
Pay gap reporting
Austria is expected to expand its existing reporting obligations to align with the Directive. Employers may need to report mean and median gender pay gaps, bonus gaps, and pay distribution across employee groups. Where unjustified pay gaps of at least 5% are identified, employers may be required to carry out joint pay assessments and corrective actions.
Enforcement and sanctions
While details are still pending, Austria is expected to introduce stronger enforcement mechanisms, including compensation rights and a greater burden on employers to prove compliance with equal pay obligations.
Timeline and preparation
Although the final legislation has not yet been published, the implementation deadline remains June 2026. Employers should begin preparing by reviewing pay structures, job architecture, reporting capabilities, and recruitment practices to reduce compliance and litigation risk.
Overall, the Austrian implementation is expected to strengthen existing transparency rules and move employers toward more structured, evidence-based pay practices focused on fairness, comparability, and gender neutrality.
Belgium
Belgium is currently working on the implementation of the EU Pay Transparency Directive, with national legislation expected before the June 2026 deadline. While Belgium already has a relatively developed equal pay framework, including gender pay gap legislation from 2012, the Directive will introduce broader transparency obligations, stronger employee rights, and additional enforcement measures.
Pay transparency in recruitment
Employers are expected to provide salary information to candidates before salary negotiations begin, including starting salaries or salary ranges. Questions about a candidate’s salary history are expected to be prohibited. Belgium is also expected to tighten requirements around gender-neutral job advertisements and recruitment practices.
Job evaluation and equal work
Employers will need to demonstrate that pay differences are based on objective, gender-neutral criteria. This increases the importance of structured job architecture, role classification systems, and documented pay-setting processes based on work of equal value. Belgium’s existing collective bargaining and sector classification systems are also expected to be reviewed from a gender-neutral perspective.
Employee right to pay information
Employees are expected to gain stronger rights to request information about their own pay level and average pay levels for comparable roles. Employers will need to ensure that pay criteria and progression frameworks are transparent and accessible.
Pay gap reporting
Belgium already has gender pay gap reporting obligations, but these are expected to expand under the Directive. Employers may need to report gender pay gaps, bonus gaps, and pay distribution data across employee categories. Where unjustified pay gaps are identified, employers may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
Belgium is expected to strengthen enforcement mechanisms and sanctions for non-compliance, including compensation rights for employees and increased employer responsibility in equal pay disputes. Discussions continue around avoiding unnecessary administrative burden while ensuring effective enforcement.
Timeline and preparation
Although parts of the Directive have already been implemented for certain public-sector employers, Belgium has not yet published a final private-sector implementation law. Nevertheless, employers are strongly encouraged to prepare ahead of June 2026 by reviewing pay structures, recruitment practices, reporting capabilities, and internal job evaluation systems.
Overall, the Belgian implementation is expected to build on existing equal pay legislation while introducing more detailed transparency, reporting, and governance obligations designed to strengthen pay equity and accountability in practice.
Bulgaria
Bulgaria is currently in the final stages of implementing the EU Pay Transparency Directive. While the country had previously made limited progress toward transposition, draft amendments to the Labour Code and the Protection Against Discrimination Act were published for public consultation in May 2026. The legislation is expected to be adopted before the EU deadline of 7 June 2026.
Pay transparency in recruitment
Employers will be expected to provide salary information during recruitment, including salary levels or salary ranges before employment begins. The draft legislation also prohibits asking candidates about their previous remuneration and requires the use of gender-neutral job advertisements and recruitment processes.
Job evaluation and equal work
Employers will need to ensure that pay-setting systems are based on objective, gender-neutral criteria. The draft legislation highlights factors such as responsibility, complexity, effort, qualifications, and working conditions when assessing work of equal value. This is expected to increase the importance of structured job architecture and documented compensation processes.
Employee right to pay information
Employees are expected to gain the right to request information about average pay levels for comparable categories of workers, broken down by gender. Employers will also need to provide greater transparency around the criteria used for pay-setting and salary progression.
Pay gap reporting
Bulgaria currently has no mandatory gender pay gap reporting regime for private employers. Under the new framework, employers with at least 100 employees will be required to report on gender pay gaps, including differences in fixed and variable pay, bonus payments, and pay distribution across employee groups. Where unjustified pay gaps of 5% or more are identified, employers may be required to carry out joint pay assessments and corrective measures.
Enforcement and sanctions
The new rules are expected to strengthen enforcement of equal pay rights through compensation mechanisms, greater transparency obligations, and a shift in the burden of proof toward employers in discrimination cases. Further details on penalties are expected once the final legislation is adopted.
Timeline and preparation
The draft legislation is currently under public consultation, with implementation targeted for June 2026. Reporting obligations for larger employers are expected to begin in 2027, while reporting requirements for employers with 100–149 employees are expected to apply from 2031. Employers should begin reviewing pay structures, recruitment practices, job evaluation frameworks, and data readiness well before the new requirements take effect.
Overall, the Bulgarian implementation represents a significant shift from general equal pay protections toward a more structured transparency and reporting framework, requiring employers to actively demonstrate that pay decisions are objective, consistent, and gender-neutral.
Croatia
Croatia has not yet adopted final legislation implementing the EU Pay Transparency Directive, but preparations are underway and transposition is expected to be completed in line with the EU deadline of 7 June 2026. While Croatian labour law already prohibits pay discrimination, the Directive will introduce significantly broader transparency, reporting, and compliance obligations for employers.
Pay transparency in recruitment
Employers are expected to provide candidates with information about the initial salary or salary range before employment begins. The new rules are also expected to prohibit employers from asking applicants about their salary history and require recruitment processes to be based on gender-neutral criteria.
Job evaluation and equal work
Employers will need to ensure that pay decisions are based on objective and gender-neutral factors. This will increase the importance of structured job evaluation frameworks, clear role definitions, and documented compensation practices that can demonstrate equal pay for equal work or work of equal value.
Employee right to pay information
Employees are expected to gain the right to request information regarding their own pay level and average pay levels for workers performing the same work or work of equal value, broken down by gender. Employers will also need to provide information about the criteria used for determining pay and career progression.
Pay gap reporting
Croatia currently does not have the extensive pay transparency reporting requirements introduced by the Directive. Under the new framework, employers meeting the relevant employee thresholds will be required to report gender pay gap data, including differences in fixed and variable remuneration. Where unjustified pay gaps of at least 5% are identified, employers may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
The Croatian implementation is expected to strengthen enforcement of equal pay rights through increased transparency obligations, compensation rights for affected employees, and a shift in the burden of proof toward employers in pay discrimination cases. Penalties for non-compliance are expected to be introduced as part of the transposition legislation.
Timeline and preparation
Although final legislative proposals have not yet been published, employers should begin preparing ahead of the June 2026 deadline. Key preparation areas include reviewing pay structures, establishing objective job evaluation methodologies, assessing gender pay gaps, and ensuring HR systems can support future reporting requirements.
Overall, the Croatian implementation is expected to move beyond existing anti-discrimination rules by introducing proactive transparency and reporting obligations, requiring employers to demonstrate that pay practices are fair, objective, and gender-neutral.
Cyprus
Cyprus has not yet published final legislation implementing the EU Pay Transparency Directive, but the government is expected to transpose the Directive before the EU deadline of 7 June 2026. While Cypriot law already prohibits gender-based pay discrimination, the new rules will introduce significantly greater transparency obligations, stronger employee rights, and formal pay gap reporting requirements for larger employers.
Pay transparency in recruitment
Employers are expected to provide candidates with information about the initial salary or salary range before employment begins. The new rules are also expected to prohibit employers from asking applicants about their salary history and require recruitment processes and job advertisements to be gender-neutral.
Job evaluation and equal work
Employers will need to ensure that pay decisions are based on objective, gender-neutral criteria. This will increase the importance of structured job evaluation systems, clear role definitions, and documented compensation practices capable of demonstrating equal pay for equal work or work of equal value.
Employee right to pay information
Employees are expected to gain the right to request information about their individual pay level and the average pay levels of workers performing the same work or work of equal value, broken down by gender. Employers will also be required to provide information about the criteria used for determining pay, pay progression, and promotion opportunities.
Pay gap reporting
Cyprus currently does not require the extensive pay transparency reporting envisaged by the Directive. Under the new framework, employers meeting the applicable employee thresholds will be required to report gender pay gap data, including differences in fixed and variable remuneration. Where an unjustified gender pay gap of at least 5% is identified, employers may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
The Cypriot implementation is expected to strengthen enforcement mechanisms through enhanced employee rights, compensation claims for victims of pay discrimination, and a shift in the burden of proof toward employers. Financial penalties and other sanctions for non-compliance are expected to be introduced as part of the transposition legislation.
Timeline and preparation
Although detailed draft legislation has not yet been published, employers should begin preparing ahead of the June 2026 deadline. Priority areas include reviewing pay structures, implementing objective job evaluation frameworks, assessing potential pay gaps, and ensuring that HR and payroll systems can support future reporting requirements.
Overall, the Cypriot implementation is expected to transform equal pay obligations from a largely reactive anti-discrimination framework into a proactive transparency and compliance regime, requiring employers to demonstrate that pay practices are fair, objective, and gender-neutral.
Czech Republic
The Czech Republic has not yet adopted final legislation implementing the EU Pay Transparency Directive, but the government is expected to transpose the Directive before the 7 June 2026 deadline. Existing Czech labour law already contains equal pay provisions, including requirements for equal remuneration for equal work and work of equal value. However, the Directive will introduce substantially broader transparency, reporting, and compliance obligations for employers.
Pay transparency in recruitment
Employers are expected to provide candidates with information about the starting salary or salary range before employment begins or before salary negotiations take place. Employers will also be prohibited from asking applicants about their salary history. Recruitment processes and job advertisements will need to be gender-neutral.
Job evaluation and equal work
The Czech Labour Code already contains detailed provisions on equal pay for equal work and work of equal value. The implementation of the Directive is expected to place greater emphasis on documented, objective, and gender-neutral job evaluation systems. Employers will need to demonstrate that pay differences are justified by legitimate factors such as skills, responsibility, effort, and working conditions.
Employee right to pay information
Employees are expected to gain the right to request information about their individual pay level and average pay levels for comparable roles, broken down by gender. Employers will also need to make available the criteria used to determine pay, pay progression, and career advancement.
Pay gap reporting
The Czech Republic does not currently require gender pay gap reporting for private-sector employers. Under the Directive, employers meeting the applicable employee thresholds will be required to report gender pay gap data, including information on fixed and variable remuneration and pay distribution across employee categories. Where unjustified gender pay gaps of at least 5% are identified, employers may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
The implementation is expected to strengthen enforcement of equal pay rights through enhanced transparency obligations, compensation rights for affected employees, and a shift in the burden of proof toward employers in pay discrimination disputes. Additional penalties for non-compliance are expected to be introduced through the transposition legislation.
Timeline and preparation
Although no final implementation law has yet been adopted, employers should begin preparing ahead of the June 2026 deadline. Priority areas include reviewing pay structures, documenting pay-setting criteria, establishing robust job evaluation methodologies, and ensuring that HR systems can support future reporting and disclosure requirements.
Overall, the Czech implementation is expected to build on the country’s existing equal pay framework while introducing significantly greater transparency and accountability, requiring employers to proactively demonstrate that pay decisions are objective, consistent, and gender-neutral.
Denmark
Denmark has not yet adopted final legislation implementing the EU Pay Transparency Directive, but preparations are well underway. The Danish government established a working group with labour market representatives to assess how the Directive should be incorporated into Danish law. While Denmark already has a strong framework for equal pay and gender equality, the Directive will introduce new transparency obligations, employee rights, and reporting requirements that go beyond the current rules.
Pay transparency in recruitment
Employers are expected to provide information about the starting salary or salary range before employment begins or before salary negotiations take place. Employers will also be prohibited from asking candidates about their salary history. Recruitment procedures and job advertisements will need to be based on gender-neutral principles.
Job evaluation and equal work
Denmark already requires equal pay for men and women performing the same work or work of equal value. The Directive is expected to increase the focus on structured and documented job evaluation systems that use objective, gender-neutral criteria. Employers will need to demonstrate how pay decisions are made and ensure that any differences can be objectively justified.
Employee right to pay information
Employees will gain the right to request information about their own pay level and the average pay levels of colleagues performing the same work or work of equal value, broken down by gender. Employers will also be required to provide information about the criteria used to determine pay and career progression.
Pay gap reporting
Denmark already has gender pay gap reporting obligations for certain employers through the Danish Statistics Act and Equal Pay Act. However, the Directive is expected to expand reporting requirements by introducing additional metrics and harmonised reporting standards. Employers with significant unexplained pay gaps may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
The Danish implementation is expected to strengthen enforcement mechanisms by enhancing employees’ access to information and compensation. Employers will face a greater burden of proving compliance in equal pay disputes, and additional sanctions may be introduced for breaches of the new transparency requirements.
Timeline and preparation
Final legislation is expected before the EU implementation deadline of 7 June 2026. Employers should already be reviewing pay structures, job evaluation methodologies, recruitment practices, and reporting capabilities to ensure readiness for the new requirements.
Overall, the Danish implementation is expected to build on an already mature equal pay framework while introducing greater transparency, documentation, and accountability, requiring employers to proactively demonstrate that pay practices are fair, objective, and gender-neutral.
Estonia
Estonia has not yet adopted final legislation implementing the EU Pay Transparency Directive, but preparations are ongoing and transposition is expected before the EU deadline of 7 June 2026. While Estonian law already prohibits gender-based pay discrimination and promotes equal treatment in employment, the Directive will introduce new transparency requirements, employee information rights, and gender pay gap reporting obligations that go beyond the current framework.
Pay transparency in recruitment
Employers are expected to provide information about the starting salary or salary range before employment begins or before salary negotiations take place. Employers will also be prohibited from asking candidates about their salary history. Job advertisements and recruitment processes will need to be based on gender-neutral criteria.
Job evaluation and equal work
Estonian employers will need to ensure that pay decisions are based on objective and gender-neutral criteria. The Directive is expected to increase the importance of structured job evaluation systems, documented pay-setting processes, and clear role definitions that support the assessment of equal work and work of equal value.
Employee right to pay information
Employees are expected to gain the right to request information about their individual pay level and the average pay levels for workers performing the same work or work of equal value, broken down by gender. Employers will also need to provide information about the criteria used to determine pay and career progression.
Pay gap reporting
Estonia currently does not have the comprehensive pay gap reporting regime required under the Directive. Employers meeting the applicable employee thresholds will be required to report gender pay gap information, including differences in fixed and variable remuneration and the distribution of employees across pay quartiles. Where unjustified gender pay gaps of at least 5% are identified, employers may be required to conduct joint pay assessments and take corrective action.
Enforcement and sanctions
The Estonian implementation is expected to strengthen enforcement mechanisms by improving employees’ access to information and compensation. The burden of proof in equal pay disputes will shift more strongly toward employers, requiring them to demonstrate that pay differences are based on objective and gender-neutral factors. Additional sanctions for non-compliance are expected to be introduced.
Timeline and preparation
Although final legislation has not yet been published, employers should begin preparing ahead of the June 2026 deadline. Key preparation areas include reviewing compensation structures, implementing objective job evaluation frameworks, assessing potential pay gaps, and ensuring that HR and payroll systems can support future reporting requirements.
Overall, the Estonian implementation is expected to strengthen existing equal treatment protections by introducing greater transparency and accountability, requiring employers to actively demonstrate that pay decisions are fair, objective, and gender-neutral.
Finland
Finland has not yet adopted final legislation implementing the EU Pay Transparency Directive, but preparations are progressing and the government is expected to complete transposition before the EU deadline of 7 June 2026. Finland already has a well-established framework for promoting pay equality, including mandatory equality plans and pay surveys for many employers. However, the Directive will introduce additional transparency obligations, employee rights, and reporting requirements that go beyond the current legislation.
Pay transparency in recruitment
Employers are expected to provide information about the starting salary or salary range before employment begins or before salary negotiations take place. Employers will also be prohibited from asking candidates about their salary history. Recruitment practices and job advertisements will need to be based on gender-neutral criteria.
Job evaluation and equal work
Finland already requires employers to promote pay equality and conduct pay surveys as part of equality planning obligations. The Directive is expected to increase the focus on structured, objective, and gender-neutral job evaluation systems. Employers will need to be able to demonstrate that pay differences are justified by legitimate factors and that roles of equal value are assessed consistently.
Employee right to pay information
Employees will gain the right to request information about their own pay level and the average pay levels of workers performing the same work or work of equal value, broken down by gender. Employers will also need to provide information about the criteria used to determine pay levels, pay progression, and career advancement.
Pay gap reporting
While many Finnish employers already conduct internal pay surveys, the Directive will introduce formal gender pay gap reporting requirements for employers meeting the applicable employee thresholds. Reporting will cover metrics such as gender pay gaps, differences in variable remuneration, and employee distribution across pay levels. Where unjustified gender pay gaps of at least 5% are identified, employers may be required to carry out joint pay assessments and implement corrective measures.
Enforcement and sanctions
The Finnish implementation is expected to strengthen enforcement of equal pay rights by increasing transparency obligations and improving employees’ access to information and compensation. Employers will face a greater burden of proof in equal pay disputes and may be subject to additional sanctions for non-compliance with reporting and transparency requirements.
Timeline and preparation
Final legislation is expected before the June 2026 implementation deadline. Employers should begin reviewing pay structures, equality plans, job evaluation methodologies, and reporting capabilities to ensure compliance with the new requirements. Particular attention should be paid to documenting pay-setting criteria and identifying any unexplained pay gaps.
Overall, the Finnish implementation is expected to build on the country’s existing equality framework while introducing greater transparency and accountability, requiring employers to proactively demonstrate that pay practices are fair, objective, and gender-neutral.
France
France has not yet adopted final legislation implementing the EU Pay Transparency Directive, but it is well positioned for transposition due to its existing gender equality framework. French employers are already subject to significant pay equity obligations, including the Gender Equality Index (Index de l’égalité professionnelle), mandatory corrective measures, and reporting requirements. However, the Directive will introduce additional transparency rights, broader reporting obligations, and new requirements relating to recruitment and pay disclosure.
Pay transparency in recruitment
Employers will be required to provide candidates with information about the starting salary or salary range before employment begins or before salary negotiations take place. Employers will also be prohibited from asking applicants about their salary history. Recruitment processes and job advertisements will need to be based on gender-neutral criteria.
Job evaluation and equal work
France already requires equal pay for equal work and work of equal value. The Directive is expected to increase the importance of structured and documented job evaluation systems that use objective, gender-neutral criteria. Employers will need to demonstrate how pay decisions are made and ensure that any pay differences can be objectively justified.
Employee right to pay information
Employees will gain the right to request information about their individual pay level and the average pay levels of workers performing the same work or work of equal value, broken down by gender. Employers will also be required to provide information about the criteria used for determining pay, pay progression, and career development.
Pay gap reporting
France already requires many employers to calculate and publish their Gender Equality Index. The Directive is expected to expand existing obligations by introducing additional reporting metrics, including gender pay gap data, differences in variable remuneration, and pay distribution across employee groups. Where unjustified gender pay gaps of at least 5% are identified, employers may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
France already has established enforcement mechanisms for pay equality, including financial penalties for employers that fail to meet certain obligations. The implementation of the Directive is expected to strengthen employees’ rights to compensation and increase employers’ responsibility to demonstrate compliance in equal pay disputes. Additional transparency-related sanctions may also be introduced.
Timeline and preparation
The French government is expected to adopt transposition measures before the EU deadline of 7 June 2026. Employers should review existing compliance processes, including Gender Equality Index reporting, pay-setting practices, job evaluation methodologies, and recruitment procedures to identify any gaps between current requirements and the new Directive obligations.
Overall, the French implementation is expected to build on an already mature pay equity framework while introducing greater transparency and employee access to pay information, requiring employers to demonstrate more clearly that pay decisions are objective, fair, and gender-neutral.
Germany
Germany has not yet adopted final legislation implementing the EU Pay Transparency Directive, but the government is expected to publish a transposition bill ahead of the EU deadline of 7 June 2026. Germany already has several pay transparency measures in place, most notably the Pay Transparency Act (Entgelttransparenzgesetz), which gives certain employees the right to request pay information. However, the Directive will require significant expansion of existing transparency, reporting, and enforcement obligations.
Pay transparency in recruitment
Employers will be required to provide candidates with information about the starting salary or salary range before employment begins or before salary negotiations take place. Employers will also be prohibited from asking applicants about their salary history. Recruitment processes and job advertisements will need to be based on objective and gender-neutral criteria.
Job evaluation and equal work
Germany already prohibits gender-based pay discrimination and requires equal pay for equal work and work of equal value. The Directive is expected to increase the focus on structured job evaluation systems and documented pay-setting processes. Employers will need to demonstrate that pay differences are based on objective, gender-neutral criteria such as skills, responsibility, effort, and working conditions.
Employee right to pay information
The existing right to information under the Pay Transparency Act is expected to be significantly expanded. Employees will gain broader access to information about their own pay level and the average pay levels of workers performing the same work or work of equal value, broken down by gender. Employers will also be required to provide information about the criteria used to determine pay and pay progression.
Pay gap reporting
Germany already requires certain large employers to publish reports on gender equality and equal pay. Under the Directive, reporting obligations will become more detailed and apply according to the EU thresholds. Employers will be required to report gender pay gap data, including differences in fixed and variable remuneration and pay distribution across employee categories. Where unjustified gender pay gaps of at least 5% are identified, employers may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
The German implementation is expected to strengthen enforcement mechanisms by increasing transparency obligations, improving employees’ access to compensation, and shifting the burden of proof more strongly toward employers in equal pay disputes. Additional sanctions for non-compliance with reporting and transparency requirements are also expected.
Timeline and preparation
Although Germany already has a pay transparency framework in place, employers should not assume that existing compliance measures will be sufficient. Ahead of the June 2026 deadline, employers should review pay structures, job evaluation methodologies, recruitment processes, and reporting capabilities to identify gaps between current practices and the Directive’s requirements.
Overall, the German implementation is expected to build on the existing Pay Transparency Act while introducing broader transparency rights, more extensive reporting obligations, and stronger enforcement measures, requiring employers to proactively demonstrate that pay decisions are fair, objective, and gender-neutral.
Greece
Greece has not yet adopted final legislation implementing the EU Pay Transparency Directive, but the government is expected to complete transposition before the EU deadline of 7 June 2026. Greek employment law already prohibits gender-based pay discrimination and provides for equal treatment in the workplace. However, the Directive will introduce significantly broader transparency obligations, stronger employee rights, and formal pay gap reporting requirements that go beyond the current framework.
Pay transparency in recruitment
Employers will be required to provide candidates with information about the starting salary or salary range before employment begins or before salary negotiations take place. Employers will also be prohibited from asking applicants about their salary history. Recruitment procedures and job advertisements will need to be based on objective and gender-neutral criteria.
Job evaluation and equal work
Greek employers will need to ensure that pay decisions are based on objective, gender-neutral criteria and that differences in remuneration can be justified by legitimate factors. The Directive is expected to increase the importance of structured job evaluation systems, clear role definitions, and documented pay-setting processes that support equal pay for equal work and work of equal value.
Employee right to pay information
Employees will gain the right to request information about their individual pay level and the average pay levels of workers performing the same work or work of equal value, broken down by gender. Employers will also be required to provide information about the criteria used to determine pay, pay progression, and promotion opportunities.
Pay gap reporting
Greece does not currently have the comprehensive pay gap reporting framework required by the Directive. Under the new rules, employers meeting the applicable employee thresholds will be required to report gender pay gap data, including differences in fixed and variable remuneration and employee distribution across pay categories. Where unjustified gender pay gaps of at least 5% are identified, employers may be required to conduct joint pay assessments and implement corrective measures.
Enforcement and sanctions
The Greek implementation is expected to strengthen enforcement of equal pay rights through enhanced transparency obligations, improved access to compensation for affected employees, and a shift in the burden of proof toward employers in pay discrimination disputes. Additional penalties for non-compliance are expected to be introduced as part of the transposition legislation.
Timeline and preparation
Although final implementing legislation has not yet been published, employers should begin preparing ahead of the June 2026 deadline. Priority areas include reviewing compensation structures, documenting pay-setting criteria, implementing objective job evaluation methodologies, and ensuring that HR and payroll systems can support future reporting requirements.
Overall, the Greek implementation is expected to move beyond existing anti-discrimination protections by introducing proactive transparency and reporting obligations, requiring employers to demonstrate that pay practices are fair, objective, and gender-neutral.
Hungary
Hungary has not yet published draft legislation implementing the EU Pay Transparency Directive. While Hungary is legally required to transpose the Directive by 7 June 2026, as of June 2026 there is no publicly available implementation bill, and local legal experts have questioned whether the deadline will be met.
No draft legislation published
Unlike several other EU Member States, Hungary has not yet released draft legislation or opened a formal public consultation on the implementation of the Directive. As a result, there is currently limited visibility into how the government intends to transpose key provisions or whether it will go beyond the Directive’s minimum requirements.
Implementation discussions are underway
Hungarian legal commentators expect amendments to existing labour and anti-discrimination legislation rather than the introduction of a standalone pay transparency law. However, the scope and timing of these changes remain unclear.
Uncertainty around the June 2026 deadline
Although Hungary is legally required to transpose the Directive by 7 June 2026, local experts have noted that it remains uncertain whether the legislative process will be completed in time. No official implementation timetable has been published.
Existing equal pay framework may reduce the scale of change
Hungarian labour law already prohibits discrimination in pay and employment. However, significant changes will still be required to introduce the Directive’s transparency obligations, employee information rights, recruitment requirements, and gender pay gap reporting framework.
Limited guidance for employers so far
Because no draft legislation has been published, employers currently have little certainty regarding:
- Reporting methodologies
- Definitions of worker categories
- National enforcement mechanisms
- Penalties for non-compliance
- Whether Hungary will introduce any country-specific requirements beyond the Directive
What employers should do now
Despite the legislative uncertainty, employers should begin preparing for the Directive’s requirements by reviewing:
- Job architecture and job evaluation frameworks
- Pay-setting and pay progression criteria
- Recruitment processes and salary disclosure practices
- Pay gap analysis capabilities
- HR and payroll data quality
Outlook
Hungary remains legally bound by the EU implementation deadline of 7 June 2026, but as of June 2026 there is no published draft legislation and no clear indication that the legislative process will be completed on time. Employers should therefore monitor developments closely while preparing for compliance based on the Directive’s requirements.
Ireland
Ireland is now widely expected to miss the EU Pay Transparency Directive transposition deadline of 7 June 2026. While the government has begun partial implementation work and published draft measures covering some recruitment-related obligations, no full implementation bill has been published and officials have acknowledged that transposition will occur on a phased basis.
Ireland has signalled that the deadline will not be fully met
The Department of Children, Disability and Equality has confirmed that implementation will occur on a phased basis and that not all elements of the Directive will be in force by 7 June 2026. Multiple Irish legal and HR sources now state that Ireland is unlikely to complete transposition on time.
Some draft legislative measures already exist
In January 2025, the government published the General Scheme of the Equality (Miscellaneous Provisions) Bill, which includes measures intended to implement Article 5 of the Directive relating to pay transparency before employment. These proposals cover salary information during recruitment and restrictions on salary history questions.
No full Pay Transparency Bill has been published
Although a Pay Transparency Bill has been anticipated, no complete implementing legislation has been published. The legislation was not included in the Government’s priority summer legislative programme, reinforcing expectations of delay.
Existing Irish legislation already covers part of the framework
Ireland is not starting from scratch. The Gender Pay Gap Information Act 2021 already introduced mandatory gender pay gap reporting for many employers. Government officials have pointed to this existing framework as partial implementation of the Directive’s objectives.
Government guidance has also been delayed
Officials have indicated that implementation work has been affected by delays in EU-level guidance, including the Irish gender-neutral job evaluation toolkit, which was only finalised in spring 2026. Employer workshops and guidance programmes are expected to continue through 2026.
Areas where implementation direction is already clear
Although final legislation is not yet available, Irish commentary and draft materials indicate that future legislation is expected to include:
- Salary information requirements during recruitment
- A prohibition on asking candidates about salary history
- Expanded employee rights to request pay information
- More detailed gender pay gap reporting obligations
- Greater requirements to justify pay differences using objective and gender-neutral criteria
- Joint pay assessment requirements where significant unexplained pay gaps exist
What employers should do now
Irish legal advisers are consistently recommending that employers begin preparations despite the legislative delay by reviewing:
- Pay structures and grading systems
- Job evaluation methodologies
- Recruitment processes
- Gender pay gap reporting readiness
- Pay-setting and pay progression criteria
- HR and payroll data quality
Outlook
Ireland remains legally required to transpose the Directive by 7 June 2026. However, the government has effectively acknowledged that full implementation will not be completed by that date. The current expectation among Irish employment law experts is that implementation will continue on a phased basis after June 2026, with employers encouraged to prepare before final legislation is adopted.
Italy
Italy is one of the few EU Member States that appears likely to complete implementation of the EU Pay Transparency Directive on time. Unlike many countries that are still in consultation or draft stages, Italy has already approved its implementing decree at government level and is widely viewed by legal experts as being on track to meet the 7 June 2026 transposition deadline.
Implementing decree approved by the Council of Ministers
Italy’s Council of Ministers approved the legislative decree implementing the Directive on 30 April 2026. Although publication in the Official Gazette is still pending, the legislation has already completed the key stages of the national approval process.
Italy is considered one of the few countries likely to meet the deadline
Multiple legal commentators identify Italy as one of only a small number of Member States expected to have full implementing legislation in place by 7 June 2026. This contrasts with most EU countries, where draft legislation is still pending or delays are already expected.
National collective agreements play a central role
One of the most distinctive features of the Italian approach is the strong reliance on National Collective Bargaining Agreements (NCBAs) when assessing “equal work” and “work of equal value.” Employers may use NCBA classification systems as a primary reference point for pay comparisons and worker categorisation.
Italy has adopted several country-specific adjustments
The approved decree does not simply copy the Directive. Notable Italian features include:
- A narrower definition of “pay level” for certain employee information requests
- A limit of one employee pay information request per year
- Specific procedural rules for responding to pay transparency requests
- Continued reliance on collective bargaining structures when assessing equal value work.
Areas where the Italian approach is already clear
Recruitment transparency obligations
The decree requires employers to provide salary information during recruitment and strengthens obligations around pay disclosure in job advertisements. Questions about salary history are expected to be prohibited.
Employee information rights
Employees will have rights to request pay information, although Italy has introduced a limitation allowing such requests only once every twelve months. Employers will need formal processes to manage these requests within statutory deadlines.
Gender pay gap reporting
Italy already has existing gender equality reporting obligations through Law 162/2021 and the Equal Pay Certification framework. The new decree expands transparency obligations and aligns reporting requirements with the Directive.
Joint pay assessments and corrective measures
The decree includes mechanisms for addressing unjustified pay disparities and provides a framework for employer responses where pay discrimination concerns are identified.
What employers should do now
Because implementation is now largely settled, Italian employers should focus on operational readiness rather than waiting for further legislative clarity. Key preparation areas include:
- Reviewing collective bargaining classifications and grading structures
- Assessing pay-setting and pay progression criteria
- Preparing recruitment processes for salary disclosure requirements
- Establishing procedures for employee pay information requests
- Reviewing gender pay gap reporting capabilities
- Auditing pay data and documentation supporting pay decisions.
Outlook
Italy is currently one of the strongest examples of a Member State likely to complete transposition on time. The implementing decree has already received final government approval, and local legal experts generally view Italy as being on track to meet the 7 June 2026 deadline. Employers should therefore assume that the new requirements will take effect as planned and continue preparing for compliance.
Latvia
Latvia has not yet adopted final legislation implementing the EU Pay Transparency Directive, but unlike many Member States, the government has published draft amendments and begun the formal legislative process. As of June 2026, Latvia appears to be making active progress toward transposition, although it remains unclear whether all legislation will be formally adopted before the 7 June 2026 deadline.
Draft legislation has been published
Latvia has published draft amendments to its labour legislation to implement the Directive. This places Latvia ahead of a number of Member States that have not yet released any legislative proposals.
Government has begun formal transposition work
The Ministry of Welfare has been leading the implementation process, and the proposed amendments have progressed through consultation and review stages. This provides greater visibility into Latvia’s intended approach than is currently available in many other EU countries.
On-time implementation remains possible, but not guaranteed
Because draft legislation is already available, Latvia is generally viewed as being further advanced than countries where no draft exists. However, as of June 2026, the legislative process had not yet been fully completed, making it difficult to confirm whether final adoption will occur before the EU deadline.
Implementation largely follows the Directive framework
Based on the published proposals, Latvia is not expected to introduce major deviations from the Directive. Instead, the draft legislation primarily focuses on incorporating the Directive’s requirements into existing labour law structures.
Areas where the Latvian approach is already clear
Pay transparency during recruitment
The draft legislation introduces requirements for employers to provide information about salary levels or salary ranges during recruitment. Employers would also be prohibited from requesting information about candidates’ salary history.
Employee rights to pay information
Employees would gain the right to request information regarding pay levels for comparable work and the criteria used to determine remuneration and career progression.
Equal pay and job evaluation requirements
Employers would be required to ensure that remuneration systems are based on objective and gender-neutral criteria. This is expected to increase the importance of documented job evaluation methodologies and transparent pay-setting processes.
Gender pay gap reporting
Latvia’s draft legislation incorporates the Directive’s reporting requirements for employers meeting the relevant employee thresholds. Employers may also be required to conduct joint pay assessments where unexplained gender pay gaps exceed the thresholds established by the Directive.
What employers should do now
Given the advanced stage of the legislative process, Latvian employers should begin preparing for compliance by:
- Reviewing job architecture and grading frameworks
- Assessing pay-setting and pay progression criteria
- Evaluating recruitment practices and salary disclosure processes
- Preparing for future pay gap reporting requirements
- Reviewing HR and payroll data quality
- Identifying potential unexplained pay gaps
Outlook
Latvia is further advanced than many EU Member States because draft implementation legislation has already been published and reviewed. While it remains uncertain whether the full legislative process will be completed before 7 June 2026, local developments suggest that Latvia is actively progressing toward transposition and is closer to implementation than countries where no draft legislation has yet appeared.
Lithuania
Lithuania is one of the most advanced EU Member States in implementing the EU Pay Transparency Directive and is currently considered likely to meet the 7 June 2026 transposition deadline. Unlike many countries that have not yet published draft legislation, Lithuania has already approved government-backed amendments and progressed them through the legislative process. Several legal and compliance trackers identify Lithuania as one of the few countries still on track for timely implementation.
Draft legislation has already been approved by the Government
On 18 March 2026, Lithuania’s Government approved amendments to the Labour Code implementing the Directive. The legislation was then forwarded to Parliament (Seimas) for final approval.
Lithuania is widely viewed as being on track to meet the deadline
Several international legal trackers identify Lithuania as one of the few Member States likely to complete transposition by 7 June 2026. This places Lithuania significantly ahead of many EU countries where no draft legislation has yet been published.
Lithuania already had substantial pay transparency rules before the Directive
Since 2019, Lithuanian employers have already been required to:
- Include salary information in job advertisements
- Refrain from asking candidates about salary history
In addition, employers with 20 or more employees already operate under pay system and pay gap assessment requirements. The Directive implementation therefore builds on an existing national framework rather than creating an entirely new system.
Final approval may already have been completed
Some recent trackers report that Lithuania’s Parliament approved the amendments in May 2026, making Lithuania one of the first Member States to formally enact implementation legislation. However, reporting across sources is not yet fully aligned, and employers should continue monitoring final publication and entry-into-force details.
Areas where the Lithuanian approach is already clear
All employers will need formal remuneration systems
One notable feature of the Lithuanian approach is that remuneration system requirements would apply to all employers, not only larger organisations. Employers will need documented remuneration frameworks based on objective and gender-neutral criteria.
Detailed job classification requirements
Employers will be required to classify jobs into categories based on equal value work using objective criteria such as:
- Skills
- Qualifications
- Responsibility
- Effort
- Working conditions
Lithuania’s draft legislation provides unusually detailed guidance on how equal value assessments should be carried out.
Expanded employee information rights
Employees would gain rights to request pay comparisons and average pay information for comparable work categories. Employers would also be required to inform employees annually of these rights.
A highly centralised reporting model
Lithuania is developing one of the most centralised reporting systems in the EU. Instead of relying primarily on employer-submitted reports, the State Social Insurance Fund Board (Sodra) is expected to calculate many gender pay gap indicators directly from payroll data already reported to the government. This is a distinctive feature of the Lithuanian model.
What employers should do now
Because Lithuania’s implementation is already well advanced, employers should focus on operational readiness rather than waiting for further legislative clarity. Priority areas include:
- Reviewing remuneration systems and pay structures
- Establishing objective job classification methodologies
- Assessing pay-setting and promotion criteria
- Reviewing recruitment processes
- Evaluating pay gap exposure
- Preparing payroll and HR systems for future reporting obligations
- Documenting justification for pay differences between comparable roles.
Outlook
Lithuania is currently one of the strongest examples of a Member State progressing toward timely implementation. Government-approved legislation already exists, parliamentary approval has substantially progressed, and multiple legal trackers continue to identify Lithuania as being on track to meet the 7 June 2026 deadline. Employers should therefore assume that the new framework will take effect largely as planned and continue preparing for compliance.
Luxembourg
Luxembourg has not yet published draft legislation implementing the EU Pay Transparency Directive. While the government remains legally required to transpose the Directive by 7 June 2026, as of June 2026 no implementation bill has been formally introduced. Local legal advisers are actively preparing employers for compliance, but there is currently limited visibility into Luxembourg’s final legislative approach.
No draft law has been published
As of June 2026, Luxembourg has not yet released draft legislation implementing the Directive. Legal briefings in Luxembourg continue to note the absence of a formal draft law, despite the approaching deadline.
No clear indication that transposition will be completed on time
Unlike countries such as Italy or Lithuania, Luxembourg has not yet progressed to the legislative drafting stage publicly. While employers are being advised to prepare for compliance, local commentary generally focuses on readiness rather than confirming an implementation timetable. There is currently no strong public indication that Luxembourg will complete transposition before 7 June 2026.
Implementation is expected through amendments to existing labour law
Although no bill is available, legal advisers expect Luxembourg to incorporate the Directive into its existing employment and equal treatment framework rather than introducing a standalone pay transparency law. However, the structure and scope of the future legislation remain unknown.
Employers currently face significant uncertainty
Because no draft legislation has been published, key questions remain unresolved, including:
- Reporting methodologies
- Definitions of worker categories
- National enforcement mechanisms
- Penalties for non-compliance
- Whether Luxembourg will introduce requirements beyond the Directive minimum standards.
Areas where the likely direction is already clear
Even without draft legislation, Luxembourg’s Ministry of Labour and local legal commentators have identified several areas expected to be implemented:
Recruitment transparency requirements
Employers are expected to be required to provide salary information or salary ranges before employment begins and will likely be prohibited from asking candidates about previous salary history.
Employee rights to pay information
Employees are expected to gain rights to request information regarding their own pay level and average pay levels for comparable work categories, broken down by gender. Luxembourg’s Labour Ministry has already publicly referenced these future employee rights.
Gender pay gap reporting obligations
Employers with more than 100 employees are expected to become subject to formal reporting requirements under the Directive framework. Luxembourg has not yet confirmed whether it will introduce any country-specific reporting extensions beyond the Directive minimum requirements.
Greater emphasis on objective job evaluation
Luxembourg legal advisers are increasingly focusing on job architecture, role classification, and objective pay-setting criteria as core preparation areas for future compliance.
What employers should do now
Because legislative details remain uncertain, employers should focus on foundational readiness rather than waiting for a final law. Priority areas include:
- Reviewing job architecture and grading frameworks
- Assessing pay-setting and pay progression criteria
- Evaluating recruitment practices and salary disclosure processes
- Reviewing gender pay gap exposure
- Improving HR and payroll data quality
- Documenting objective justification for pay differences between comparable roles.
Outlook
Luxembourg remains legally required to transpose the Directive by 7 June 2026. However, as of June 2026 no draft implementing legislation has been published, and there is currently no strong public indication that the legislative process will be completed before the deadline. Local experts are therefore focusing on employer preparation rather than predicting timely transposition. Employers should continue monitoring developments closely while preparing based on the Directive’s expected requirements.
Malta
Malta is further advanced than many EU Member States in implementing the EU Pay Transparency Directive. Unlike countries that have not yet published draft legislation, Malta has already adopted initial legislative measures and begun formal transposition. Several legal trackers currently identify Malta as one of the countries still progressing toward the 7 June 2026 deadline, although full implementation has not yet been completed and additional legislation is still required.
Malta has already adopted its first implementing measures
On 27 June 2025, Malta adopted Legal Notice 112 of 2025, amending the Transparent and Predictable Working Conditions Regulations. These amendments introduced the country’s first Directive-related pay transparency obligations and entered into force on 27 August 2025.
Malta is further advanced than many Member States
Unlike countries where no draft legislation exists, Malta has already enacted part of its implementation framework. Several legal and compliance trackers identify Malta as one of the countries still advancing toward timely transposition.
Full transposition has not yet been completed
Although Malta has implemented some recruitment and employee information rights, multiple legal commentators note that major parts of the Directive still require additional legislation. Areas such as pay gap reporting, enforcement mechanisms, sanctions, transparency of pay-setting criteria, and joint pay assessments have not yet been fully implemented.
Malta is building on an existing equal pay framework
Malta already prohibits pay discrimination through the Employment and Industrial Relations Act and Equal Treatment in Employment Regulations. The Directive implementation therefore expands an existing legal framework rather than creating an entirely new one.
Areas where the Maltese approach is already clear
Salary disclosure obligations already exist
Job applicants now have a legal right to receive information about the starting salary or salary range before employment begins. Employers must also provide information about relevant collective agreement pay provisions where applicable.
Employees already have new pay information rights
Employees can request written information regarding their own pay level and the pay levels of workers performing the same work. Employers generally have up to two months to respond.
Additional transparency obligations are expected
Current Maltese legislation does not yet fully reflect the Directive. Future legislation is expected to introduce:
- Broader “work of equal value” comparisons
- Transparency regarding pay-setting and pay progression criteria
- Restrictions on salary history questions
- Gender pay gap reporting obligations
- Joint pay assessment requirements
- Additional enforcement mechanisms and penalties.
What employers should do now
Because part of the framework is already in force and additional legislation is expected, employers should focus on operational readiness by:
- Reviewing pay structures and grading frameworks
- Assessing recruitment and salary disclosure practices
- Evaluating pay-setting and pay progression criteria
- Preparing for future gender pay gap reporting obligations
- Reviewing HR and payroll data quality
- Identifying and documenting explanations for pay differences between comparable roles.
Outlook
Malta has made more concrete implementation progress than many EU Member States by already adopting Directive-related legislation. Local legal commentators generally view Malta as actively progressing toward compliance, and some international trackers continue to identify Malta as being among the countries still on track for implementation. However, substantial parts of the Directive remain unimplemented and will require further legislation before Malta achieves full transposition. Employers should therefore assume that additional legislative developments will follow during 2026 and continue preparing accordingly.
The Netherlands
The Netherlands is one of the few EU Member States that has openly acknowledged it will not meet the EU Pay Transparency Directive transposition deadline of 7 June 2026. Although draft legislation has already been published and revised, the Dutch government has formally postponed implementation until 1 January 2027. As a result, the Netherlands is generally viewed as being legislatively advanced but politically delayed.
The Netherlands has formally announced a delayed implementation date
In September 2025, the Ministry of Social Affairs and Employment confirmed that the Directive would not be implemented by 7 June 2026. The government’s target date for entry into force is now 1 January 2027. The Netherlands became the first EU Member State to publicly acknowledge that it would miss the Directive deadline.
Draft legislation already exists and has been revised
Unlike many countries that have not yet published implementation proposals, the Netherlands released draft legislation in March 2025, completed a public consultation process, and submitted a revised version to the Council of State in January 2026. The legislative framework is therefore relatively well developed, even though adoption has been delayed.
The European Commission has rejected the postponement
The Commission has publicly stated that Member States are still expected to meet the June 2026 deadline and has specifically criticised the Dutch delay. Legal commentators note that infringement proceedings remain possible if implementation is not completed on time.
The delay is linked to domestic political and legislative factors
Dutch legal sources point to the collapse of the coalition government in 2025 and the resulting legislative backlog as major reasons for the postponed timetable. The government has also stated that additional time is needed to create a framework that employers can implement with lower administrative burden.
Areas where the Dutch approach is already clear
A largely minimum-standard implementation model
The Dutch draft legislation generally follows the Directive closely and does not appear to introduce major country-specific obligations beyond the EU minimum requirements.
Mandatory salary transparency during recruitment
The draft bill requires employers to provide salary information or salary ranges before employment begins and prohibits asking candidates about salary history. The obligations would also apply to internal recruitment processes and certain temporary agency work situations.
Formal job evaluation and classification systems
One notable feature of the revised Dutch proposal is the requirement for employers to maintain formal job evaluation and classification systems based on objective and gender-neutral criteria. The legislation specifically refers to factors such as:
- Skills
- Effort
- Responsibility
- Working conditions.
Expanded employee information rights
Employees would gain rights to request pay information regarding comparable work categories and to receive explanations for pay differences. Importantly, employers may be required to justify pay differences even where they fall below the Directive’s 5% joint pay assessment threshold.
Reporting obligations are expected to shift forward by one year
Because implementation has been delayed, the first reporting cycle for larger employers is now expected to be based on 2027 pay data rather than 2026 data. Employers with 150 or more employees are expected to report from 2028 onward.
What employers should do now
Despite the delayed implementation date, Dutch legal advisers are consistently warning employers not to postpone preparation. Priority areas include:
- Reviewing pay structures and grading systems
- Establishing objective job evaluation methodologies
- Assessing pay-setting and promotion criteria
- Reviewing recruitment and salary disclosure practices
- Evaluating gender pay gap exposure
- Preparing HR and payroll systems for future reporting obligations
- Documenting objective justification for pay differences.
Outlook
The Netherlands is unusual because it has progressed much further legislatively than many Member States while simultaneously acknowledging that it will miss the EU deadline. Draft legislation is already well developed and the overall direction of implementation is largely known. However, the Dutch government has formally postponed implementation until 1 January 2027, and local legal experts generally treat the June 2026 deadline as unattainable under the current timetable. Employers should therefore assume that implementation is coming, but on a delayed national schedule.
Poland
Poland is one of the more advanced EU Member States in implementing the EU Pay Transparency Directive. Unlike many countries that still have no draft legislation, Poland has already adopted part of the Directive through amendments to the Labour Code and has published a broader draft law covering the remaining requirements. Based on the current legislative progress, Poland is generally viewed as one of the countries that could still complete transposition close to the 7 June 2026 deadline, although final adoption had not yet been completed as of June 2026.
Poland has already partially implemented the Directive
Poland adopted amendments to the Labour Code in 2025 introducing recruitment-related transparency obligations. These rules entered into force on 24 December 2025 and already require employers to provide pay information during recruitment and follow gender-neutral recruitment practices.
A comprehensive implementation bill has been published
On 16 December 2025, the Polish government published a draft law intended to implement the remaining provisions of the Directive, including employee pay information rights, pay gap reporting, job evaluation requirements, and enforcement mechanisms.
Poland appears further advanced than many Member States
Unlike countries where no draft legislation exists, Poland already has both enacted measures and a published implementation bill. International legal trackers generally describe Poland as actively progressing toward implementation rather than facing the legislative uncertainty seen in many other jurisdictions.
Final implementation is not yet complete
Although substantial progress has been made, the full implementing legislation had not yet been formally adopted as of June 2026. Employers should therefore continue monitoring parliamentary developments and any amendments to the draft bill.
Areas where the Polish approach is already clear
Recruitment transparency rules are already in force
Employers must provide information about remuneration during recruitment, including salary levels or salary ranges. Employers are also prohibited from asking candidates about previous pay, and recruitment processes must be gender-neutral. Poland implemented these requirements ahead of the Directive deadline.
Mandatory job evaluation and equal value assessments
The draft legislation would require employers to establish job evaluation systems capable of identifying work of equal value. Assessments must be based on objective and gender-neutral criteria, including:
- Skills
- Effort
- Responsibility
- Working conditions.
Expanded employee rights to pay information
Employees would gain rights to request information regarding pay levels and comparable work categories. The draft legislation proposes relatively short employer response deadlines compared with some other Member States.
Gender pay gap reporting obligations are already well defined
The draft legislation largely follows the Directive’s reporting structure:
- Employers with 250+ employees would report annually
- Employers with 100–249 employees would report every three years
- Joint pay assessments would be required where unexplained pay gaps of at least 5% are identified.
Poland has also developed practical implementation tools
The government has already published a draft job evaluation tool intended to help employers assess work of equal value and prepare for future compliance obligations. This is more operational guidance than has been published in many other Member States.
What employers should do now
Because implementation is already well advanced, employers should focus on operational readiness rather than waiting for complete legislative certainty. Priority areas include:
- Reviewing pay structures and grading frameworks
- Establishing formal job evaluation methodologies
- Assessing equal value work categories
- Reviewing recruitment and salary disclosure processes
- Preparing for future pay gap reporting obligations
- Evaluating HR and payroll data quality
- Documenting objective reasons for pay differences between comparable roles.
Outlook
Poland is significantly further advanced than many EU Member States because parts of the Directive have already been implemented and comprehensive draft legislation has been published. While final adoption was still pending as of June 2026, local and international legal commentators generally describe Poland as actively progressing toward implementation rather than facing major legislative uncertainty. Poland therefore remains one of the more plausible candidates for near-term transposition, even if final timing remains subject to the legislative process.
Portugal
Portugal is in a different position from many other EU Member States because it already has a substantial pay transparency and equal pay framework in place. Existing legislation, particularly Law No. 60/2018, already covers several areas addressed by the EU Pay Transparency Directive, including pay gap monitoring and employer obligations to justify certain pay differences. As a result, Portugal is generally viewed as requiring less legislative change than many other countries. However, as of June 2026, Portugal has not yet published a comprehensive draft law fully transposing the Directive.
Portugal already has significant pay transparency legislation
Portugal is often described by legal commentators as being ahead of many Member States because existing national legislation already addresses several Directive objectives. Law No. 60/2018 introduced mechanisms to identify, assess, and address gender pay differences, including obligations for employers to justify certain unexplained pay gaps. Annual government monitoring and reporting mechanisms are already in place.
No comprehensive transposition bill has been published
Despite its existing framework, Portugal has not yet published a full implementation law specifically transposing Directive (EU) 2023/970. Local legal commentary generally expects amendments to existing employment and equal pay legislation rather than the introduction of a completely new standalone law.
Portugal appears better positioned than many Member States
Because many Directive requirements already overlap with existing Portuguese rules, legal advisers generally focus less on whether Portugal will need major legislative reform and more on how existing laws will be adjusted to align fully with the Directive. Portugal is therefore not usually grouped with countries facing major structural implementation gaps.
Uncertainty remains regarding timing
Although Portugal has a strong existing framework, there is still limited public visibility regarding the final legislative timetable. As of June 2026, no final transposition law had been publicly adopted. Unlike countries such as the Netherlands, Denmark, or the Czech Republic, Portugal has not publicly announced a delayed implementation date. However, neither has it published a final implementation package.
Areas where the Portuguese approach is already clear
Existing obligations to justify pay differences
Portugal already requires employers to explain certain pay disparities between male and female employees. This existing enforcement model is likely to form part of the Directive implementation framework and means Portuguese employers are already familiar with regulatory scrutiny of pay differences.
Pay transparency obligations are expected to expand
Future amendments are expected to introduce:
- Broader employee rights to request pay information
- Recruitment-stage salary disclosure requirements
- Restrictions on salary history questions
- More formal pay-setting transparency obligations
- Expanded reporting and equal value assessment requirements.
Existing reporting infrastructure may reduce implementation burden
Portugal already publishes national pay gap monitoring data and operates mechanisms for identifying unjustified gender pay differences. This existing infrastructure may allow Portugal to implement parts of the Directive more easily than Member States that are building reporting systems from scratch.
What employers should do now
Portuguese employers should focus on reviewing whether existing compliance measures are sufficient for the Directive’s broader requirements, including:
- Job architecture and role classification systems
- Pay-setting and pay progression criteria
- Recruitment and salary disclosure practices
- Equal value work assessments
- HR and payroll data quality
- Documentation supporting pay decisions
- Gender pay gap analysis methodologies.
Outlook
Portugal is not facing the same level of implementation uncertainty as many Member States because substantial pay transparency legislation already exists. However, as of June 2026, a complete transposition law has not yet been publicly adopted. Local commentary generally suggests that Portugal will build on its existing framework rather than introduce an entirely new system, but the final legislative timetable and exact implementation model remain unclear. Portugal therefore appears better prepared than many countries, though it is not yet possible to confirm that full transposition will be completed by the 7 June 2026 deadline.
Romania
Romania is one of the more advanced EU Member States in implementing the EU Pay Transparency Directive. Unlike many countries that still have no draft legislation, Romania has already published a draft implementation law, revised it following consultation, and continued the formal legislative process. As of June 2026, Romania is generally viewed as actively progressing toward transposition, although legal experts are divided on whether the legislation will formally enter into force before the 7 June 2026 deadline.
Romania has published and revised draft implementation legislation
Romania’s Ministry of Labour published its first draft implementation law in March 2026 and subsequently released a revised version following consultation with business and social partners. The revised draft remains closely aligned with the structure and wording of the Directive.
Romania is further advanced than many Member States
Unlike countries where no draft legislation has been published, Romania has already completed consultation stages and moved into the legislative process. This provides employers with significantly greater visibility into the expected national framework.
Experts disagree on whether the deadline will be met
Some legal commentators continue to describe Romania as being on track for implementation because draft legislation has already been revised and substantially developed.
However, other trackers note that the draft legislation still requires additional governmental and parliamentary approval and therefore may not be formally adopted before 7 June 2026. Deloitte’s latest country tracker specifically states that Romania is not expected to meet the June 2026 implementation date.
Romania is largely following the Directive rather than creating a heavily customised model
Most legal analyses describe the Romanian proposal as closely aligned with the Directive’s baseline requirements. However, Romania has introduced several procedural requirements that are stricter than the Directive minimum standards.
Areas where the Romanian approach is already clear
Salary transparency during recruitment
Employers would be required to provide salary information or salary ranges before recruitment interviews. The draft legislation also prohibits asking candidates about previous salary history. Unlike some Member States, Romania would not necessarily require salary information to appear directly in job advertisements, provided it is supplied before the interview stage.
Shorter employer response deadlines than the Directive
One of the most notable Romanian deviations is timing. While the Directive allows employers up to two months to respond to employee pay information requests, Romania’s draft would require responses within 30 working days. Similar deadlines would apply to requests for clarifications regarding reported pay gap data.
Annual employee information reminders
The draft legislation would require employers to remind employees annually of their right to request pay information and explain the procedures for exercising those rights. This goes beyond the standard Directive framework.
Gender pay gap reporting obligations are already defined
The draft largely follows the Directive’s reporting structure:
- Reporting obligations would apply to employers with 100+ employees
- Reporting would begin according to the Directive timetable
- Joint pay assessments would be required where unjustified gender pay gaps of at least 5% are identified and not corrected within the required period.
Potential fines and enforcement mechanisms are already included
The draft law contains proposed sanctions for non-compliance and designates Romania’s Territorial Labour Inspectorates as enforcement authorities. Proposed penalties could reach approximately RON 30,000 (€6,000) depending on the violation.
What employers should do now
Because Romania’s draft legislation is already relatively detailed, employers should begin preparing for compliance by:
- Reviewing job architecture and grading frameworks
- Assessing pay-setting and pay progression criteria
- Reviewing recruitment and salary disclosure processes
- Evaluating pay gap exposure
- Preparing HR and payroll systems for future reporting obligations
- Establishing procedures for responding to employee pay information requests
- Documenting objective justification for pay differences between comparable roles.
Outlook
Romania is significantly further advanced than many EU Member States because draft implementation legislation has already been published, revised, and consulted upon. However, unlike countries such as Italy or Lithuania, final legislative approval has not yet been completed. As a result, the current expert view is mixed: some legal commentators continue to describe Romania as being on track for transposition, while others believe the remaining legislative steps make implementation before 7 June 2026 unlikely. Employers should therefore assume that the framework is largely settled and continue preparing, even if the final legal adoption occurs after the EU deadline.
Slovakia
Slovakia is currently the most advanced EU Member State in implementing the EU Pay Transparency Directive and is widely recognised as the first country to complete full transposition. Unlike most Member States, which are still working through draft legislation or facing delays, Slovakia has already adopted its Equal Pay Act and is considered one of the very few countries to meet the 7 June 2026 deadline on time.
Slovakia has already adopted final implementation legislation
On 15 April 2026, Slovakia’s National Council adopted the Equal Pay Act implementing the EU Pay Transparency Directive. The legislation was subsequently signed and published, with entry into force set for 7 June 2026, exactly matching the EU transposition deadline.
Slovakia is considered the first Member State to complete transposition
Multiple legal commentators describe Slovakia as the first EU Member State to fully transpose the Directive into national law. This places Slovakia significantly ahead of most other countries, many of which still have draft legislation pending or have already acknowledged implementation delays.
Local experts view implementation as completed rather than merely planned
Unlike countries where there is uncertainty around timing, Slovak implementation is no longer a question of whether the deadline will be met. The legislation has already been adopted and employers now face concrete compliance deadlines.
Slovakia has largely followed the Directive but includes several national adjustments
Most legal analyses describe the Slovak law as closely aligned with the Directive. However, Slovakia has introduced some country-specific rules, including:
- Equal pay protections extending beyond male-female comparisons to certain same-sex comparisons
- Specific deadlines for employer responses and joint pay assessments
- National reporting deadlines and procedural requirements.
Areas where the Slovak approach is already clear
Mandatory salary transparency during recruitment
Employers must provide salary information or salary ranges before interviews or in job advertisements. Employers are prohibited from asking candidates about previous salary history, and recruitment processes must use gender-neutral criteria.
Formal pay structures become mandatory
One of the most significant features of the Slovak law is the requirement for employers to maintain transparent pay structures based on objective and gender-neutral criteria. Existing employers must have functioning pay structures capable of assessing work of equal value in place by 31 July 2026.
Employee rights to pay information are clearly defined
Employees gain rights to request information about pay levels and comparable worker categories. Slovakia has introduced specific response deadlines, generally requiring employers to respond within 30 days.
Gender pay gap reporting obligations are already fixed
The reporting timetable is now established:
- Employers with 150+ employees: first report due 7 June 2027
- Employers with 250+ employees: annual reporting thereafter
- Employers with 100–149 employees: first report due 7 June 2031, then every three years.
Joint pay assessments have unusually strict deadlines
Where reporting identifies unjustified pay gaps that trigger corrective obligations, Slovakia requires joint pay assessments within a defined two-month period. Several legal commentators have noted that this is stricter than the Directive itself.
What employers should do now
Because the legislation has already been adopted, Slovak employers should focus on immediate compliance readiness rather than monitoring future legislative developments. Priority areas include:
- Reviewing pay structures and grading frameworks
- Establishing objective work-of-equal-value methodologies
- Assessing recruitment and salary disclosure practices
- Preparing for future pay gap reporting obligations
- Reviewing HR and payroll data quality
- Documenting objective justification for pay differences between comparable roles
- Preparing processes for employee pay information requests.
Outlook
Slovakia is currently the clearest example of successful and timely implementation of the EU Pay Transparency Directive. The Equal Pay Act has already been adopted and enters into force on 7 June 2026. Unlike many Member States facing uncertainty or delay, Slovakia has moved beyond the transposition phase and into practical employer compliance. Local and international legal experts consistently describe Slovakia as the first country to complete implementation and one of the very few jurisdictions that has met the Directive deadline on time.
Slovenia
Slovenia is among the more advanced EU Member States in implementing the EU Pay Transparency Directive. The government has published draft legislation and begun the formal transposition process, giving employers greater visibility into the expected national framework than in many other countries. However, as of June 2026, the legislation has not yet been formally adopted, and there remains some uncertainty about whether the full transposition process will be completed before the 7 June 2026 deadline.
Draft implementation legislation has been published
The Slovenian Ministry of Labour published draft amendments to the Employment Relationships Act and related legislation to implement the Directive. The proposals have undergone consultation with social partners and employer organisations. This places Slovenia ahead of many Member States that have not yet published draft legislation.
Slovenia is actively progressing toward implementation
Legal commentators generally view Slovenia as making meaningful progress toward transposition. Unlike countries such as Germany, Luxembourg, or Hungary, where no comprehensive draft legislation has been published, Slovenia’s proposed framework is already largely visible.
The final legislative timetable remains uncertain
Although the draft legislation is relatively advanced, final parliamentary adoption had not yet been completed as of June 2026. Local commentary generally focuses on implementation progress rather than explicitly confirming that the June 2026 deadline will be met.
The draft legislation largely follows the Directive framework
Most analyses indicate that Slovenia intends to implement the Directive relatively closely, with only limited country-specific deviations. Existing anti-discrimination and equal treatment provisions would remain in place while new transparency obligations are added.
Areas where the Slovenian approach is already clear
Pay transparency during recruitment
Employers would be required to provide information about the starting salary or salary range before employment begins. Employers would also be prohibited from requesting information about a candidate’s previous salary history. Recruitment processes and job advertisements would need to be based on gender-neutral criteria.
Employee rights to pay information
Employees would gain the right to request information regarding their own pay level and average pay levels for comparable work categories, broken down by gender. Employers would also be required to provide information about the criteria used for determining pay and pay progression.
Greater emphasis on objective job evaluation
The draft legislation strengthens requirements for objective and gender-neutral remuneration systems. Employers will need to demonstrate that pay differences are based on legitimate factors and that work of equal value is assessed consistently.
Gender pay gap reporting obligations
Employers meeting the relevant employee thresholds would become subject to the Directive’s reporting requirements. Where unjustified gender pay gaps of at least 5% are identified and cannot be objectively justified, employers may be required to carry out joint pay assessments and implement corrective measures.
Enhanced enforcement mechanisms
The draft legislation would strengthen employee access to information and compensation while increasing employers’ burden of proof in equal pay disputes. Labour Inspectorate oversight is also expected to play a key role in enforcement.
What employers should do now
Because the overall direction of the legislation is already clear, Slovenian employers should begin preparing for compliance by:
- Reviewing job architecture and grading frameworks
- Assessing pay-setting and pay progression criteria
- Evaluating recruitment and salary disclosure practices
- Reviewing gender pay gap exposure
- Preparing HR and payroll systems for future reporting obligations
- Documenting objective justification for pay differences between comparable roles
- Establishing processes for handling employee pay information requests
Outlook
Slovenia is further advanced than many EU Member States because draft implementation legislation has already been published and consulted upon. However, as of June 2026, final adoption has not yet been completed. Local experts generally view Slovenia as actively progressing toward implementation, but there is less certainty about meeting the 7 June 2026 deadline than in countries such as Slovakia, Lithuania, or Italy. Employers should therefore assume that the overall framework is unlikely to change significantly and continue preparing for compliance while monitoring the final stages of the legislative process.
Spain
Spain is one of the EU Member States best positioned for implementation of the EU Pay Transparency Directive because it already has one of Europe’s most developed pay transparency frameworks. Existing legislation, including Royal Decree 902/2020 on Equal Pay and Royal Decree 901/2020 on Equality Plans, already covers many areas addressed by the Directive. However, as of June 2026, Spain has not yet published a dedicated transposition bill, and some Directive requirements will still require legislative amendments.
Spain already has extensive pay transparency legislation
Spain introduced major pay transparency reforms in 2020 that require employers to maintain remuneration records, conduct pay audits in certain circumstances, and implement equality plans. As a result, Spain starts from a much stronger compliance position than most Member States.
No dedicated transposition bill has been published
Despite its advanced framework, Spain has not yet released a comprehensive bill implementing Directive (EU) 2023/970. Legal commentators generally expect the government to amend existing equality and employment legislation rather than create a completely new pay transparency law.
Spain is better prepared than most Member States
Many of the Directive’s core concepts already exist in Spanish law, including:
- Pay audits
- Gender pay gap analysis
- Equal value assessments
- Transparency obligations
- Employee representation involvement
As a result, implementation is expected to focus more on adapting existing requirements than creating entirely new obligations.
The timing remains uncertain
Although Spain has a strong existing framework, there is currently limited public information regarding the government’s final implementation timetable. Unlike the Netherlands, which has formally delayed implementation, Spain has not publicly announced that it will miss the deadline. However, neither has it published final transposition legislation.
Areas where the Spanish approach is already clear
Pay audits and remuneration records already exist
Spain already requires employers to maintain remuneration records showing average pay by gender. Employers subject to Equality Plan requirements must also conduct formal pay audits. These obligations go beyond what many Member States currently require.
Job evaluation methodologies are already established
Spanish equal pay legislation already requires employers to assess work of equal value using objective criteria. Government guidance and tools supporting equal value assessments are already available, making this one of the most mature aspects of Spain’s framework.
Further recruitment transparency measures are expected
While Spain already has substantial transparency requirements, amendments will likely be needed to fully implement:
- Salary disclosure requirements before employment
- Restrictions on salary history questions
- Additional employee information rights required by the Directive
Existing reporting and equality structures may reduce implementation burden
Many larger Spanish employers already operate Equality Plans, pay audits, and remuneration reporting processes. These existing systems are expected to serve as the foundation for future Directive compliance.
What employers should do now
Spanish employers should focus on assessing whether their existing compliance programmes satisfy the Directive’s additional requirements, particularly regarding:
- Job evaluation methodologies
- Remuneration records and pay audits
- Recruitment processes
- Pay-setting and pay progression criteria
- Employee information request procedures
- Gender pay gap analysis
- Documentation supporting pay decisions
For many employers, the challenge will be adapting existing systems rather than building entirely new ones.
Outlook
Spain is one of the best-prepared Member States for implementation because substantial pay transparency legislation is already in force. However, as of June 2026, no dedicated transposition legislation has been adopted and the final implementation timetable remains unclear. Unlike several Member States that are starting almost from scratch, Spain is expected to build upon its existing framework of remuneration records, pay audits, and equality plans. As a result, employers should expect refinement and expansion of current obligations rather than a fundamental redesign of the Spanish equal pay regime.
Sweden
Sweden is one of the EU Member States best positioned to implement the EU Pay Transparency Directive. The country already has a well-developed equal pay framework through the Discrimination Act (Diskrimineringslagen), including annual pay surveys (lönekartläggning), documentation requirements, and obligations to address unjustified pay differences. However, as of June 2026, Sweden has not yet adopted final legislation transposing the Directive, and the legislative process is still ongoing.
Sweden has completed a government inquiry and published proposals
In May 2025, the government-appointed inquiry (Genomförande av lönetransparensdirektivet) presented its recommendations for implementing the Directive. The inquiry proposed extensive amendments to the Discrimination Act and related legislation. This means Sweden has progressed further than many Member States that have not yet published any formal implementation proposals.
The government has not yet adopted a final bill
Although the inquiry report has been completed and circulated for consultation, the government has not yet presented a final legislative bill to Parliament. As of June 2026, implementation legislation has therefore not been formally adopted.
Experts expect implementation, but timing remains uncertain
Unlike countries such as the Netherlands, which have openly announced delays, Sweden has not publicly postponed implementation. However, the absence of a final bill means there is uncertainty about whether all legislative steps can be completed by 7 June 2026. Most Swedish legal commentators focus on preparing for the new rules rather than predicting whether the deadline will be met.
Sweden starts from a strong compliance position
Many of the Directive’s core principles already exist in Swedish law. Employers are already required to conduct annual pay surveys and analyse pay differences between women and men performing equal work or work of equal value. As a result, Sweden is expected to require fewer structural changes than many other Member States.
Areas where the Swedish approach is already clear
Expansion of existing pay survey requirements
Rather than creating an entirely new framework, Sweden is expected to build on the existing system of annual pay surveys. Employers will likely face more detailed requirements regarding documentation, methodology, and employee access to information.
Employee rights to pay information
The inquiry proposes new rights for employees to obtain information about their pay level and average pay levels for comparable work categories. This would represent a significant expansion of current Swedish transparency obligations.
Salary transparency during recruitment
The proposed legislation would require employers to provide salary information before employment begins and prohibit questions about previous salary history. These requirements do not currently exist in Swedish law and will require changes to recruitment practices.
Formal reporting obligations for larger employers
Sweden does not currently have the gender pay gap reporting framework required by the Directive. The inquiry proposes introducing reporting obligations for employers covered by the Directive’s employee thresholds, including potential joint pay assessments where significant unexplained pay gaps are identified.
Objective criteria for pay-setting and progression
Employers will be required to make information available regarding the criteria used to determine pay, pay progression, and career advancement. This is expected to be one of the more significant practical changes for Swedish employers.
What employers should do now
Swedish employers should begin preparing by:
- Reviewing existing lönekartläggning processes
- Assessing job architecture and equal value methodologies
- Documenting pay-setting and pay progression criteria
- Reviewing recruitment and salary disclosure practices
- Evaluating readiness for future reporting requirements
- Improving HR and payroll data quality
- Identifying and addressing unexplained pay gaps
For many employers, the focus will be on expanding existing compliance frameworks rather than creating entirely new ones.
Outlook
Sweden is one of the Member States best prepared for implementation because of its long-standing requirements for annual pay surveys and equal pay analysis. The government inquiry has already proposed detailed legislative changes, providing employers with substantial visibility into the future framework. However, as of June 2026, no final legislation has been adopted, and there is uncertainty about whether all legislative steps will be completed before the 7 June 2026 deadline. Employers should nevertheless assume that the inquiry’s proposals provide a strong indication of Sweden’s eventual implementation approach and continue preparing accordingly.
