OUT-LAW GUIDE 1 min. read

EU Pay Transparency Directive: implementation across EU member states

A group of colleagues brainstorming in an office. There is a screen displaying some charts in the background.

Photo: iStock


The EU Pay Transparency Directive entered into force in May 2023 with a deadline of 7 June 2026 for member states to implement local legislation in line with its requirements.

However, implementation has been slow across the EU. Some jurisdictions have formally notified the European Commission that implementation, although in progress, will not be completed by the deadline. Others are yet to publish draft legislation.

The directive (EU 2023/970) is aimed at ensuring that the right to equal pay for equal work or work of equal value between men and women is upheld across all EU member states. It introduces significant new disclosure and reporting obligations for employers, dependent on the size of the company, along with requirements to identify and correct inequalities through a joint pay evaluation exercise where a gender pay gap of more than 5% is found. Employers and job applicants will have new rights to obtain pay-related information from employers, while the burden of proof in cases involving suspected pay discrimination where the employer has not met its transparency or reporting obligations will be reversed so that the onus will be on the employer to prove the absence of direct or indirect discrimination.

For some member states, implementing the directive will require substantial changes to existing laws.

Below, we track current progress towards implementation in each EU member state along with analysis of the level of change that is expected based on any current local requirements. We also provide guidance on what employers in each jurisdiction should be doing now to prepare.

Latest news

The European Commission and European Institute for Gender Equality (EIGE) have published a step-by-step toolkit on gender neutral job evaluation and classification. The toolkit is designed to assist employers with some of their new obligations stemming from the ‘work of equal value’ concept in the directive – arguably one of its most operationally complex aspects.

The toolkit covers identifying categories of workers; designing and auditing gender neutral job evaluation schemes; pay gap analysis; and conducting joint pay assessments. It incorporates three tailored ‘pathways’ targeted at employers of different sizes and with differing levels of operational complexity.

  • Austria

    Information for Austria last updated in July 2026

    Legislative update

    No draft legislation yet.

    Level of change expected

    Medium/High change.

    Change expected

    Despite the transposition deadline of 7 June 2026 having passed, Austria has not yet transposed the EU Pay Transparency Directive into national law. No official draft legislation has been published to date.

    Under current Austrian law, companies only need to report their adjusted gender pay gap. However, the EU Pay Transparency Directive will require businesses to report the unadjusted gender pay gap. This shift will not only highlight pay differences but may also bring to light wider issues around equal access to opportunities.

    The directive will also introduce more proactive obligations. Employers are expected to take concrete steps to address any identified gender pay gaps, and the role of works councils is likely to be strengthened.

    A key change is that employees will gain the right to request written information about their own pay levels and average pay levels.

    Enforcement will also become easier for employees. Under the new rules, they will only need to demonstrate pay discrimination, and the employer must then prove that no discrimination took place. If an employer fails to meet its transparency or reporting obligations, the burden of proof will automatically shift to the employer, increasing potential legal exposure compared to the current system.

    What should employers be doing now?

    Employers should start reviewing their pay structures, policies and data systems now to ensure they can meet the new reporting and information‑sharing duties of the directive. They should also prepare to justify any gender pay gaps and take remedial action where disparities cannot be objectively explained.

  • Belgium

    Information for Belgium last updated in July 2026

    Legislative update

    Partially transposed for the public sector but no draft legislation exists for the private sector.

    Level of change expected

    Medium/High change.

    Change expected

    Belgium has partially transposed the directive for the public sector: the parliament for the French‑speaking community and the Flemish government have adopted a decree covering certain public institutions. No draft legislation exists yet for the private sector.

    The public sector decrees largely mirror the directive. Although they currently apply only to certain public bodies, they are likely indicative of how Belgium will implement the directive more broadly.

    What should employers be doing now?

    Employers should bring pay practices in line with the directive, strengthen data systems and monitor future legislative initiatives concerning the private sector.

  • Bulgaria

    Information for Bulgaria last updated in July 2026

    Legislative update

    Draft legislation has now been published. Bulgaria's Ministry of Labour and Social Policy published a draft law amending and supplementing the Protection Against Discrimination Act, intended to transpose the EU Pay Transparency Directive, for public consultation on 19 May. The consultation period was due to end on 2 June but was extended to 18 June. The draft bill provided for an entry-into-force date of 7 June 2026, but this timing was not met and the directive was not transposed by the 7 June 2026 deadline.

    Level of change expected

    Medium/High change.

    Change expected

    Bulgarian law already recognises the core principle of equal pay through its Labour Code and anti‑discrimination framework. The draft bill would introduce further alignment with the directive including rules on pay transparency before employment, access to information on average pay levels for employees performing the same work or work of equal value, gender neutral pay setting and pay progression criteria, annual employee notifications of information rights, restrictions on pay secrecy clauses, reporting on gender pay gaps and joint pay assessments where relevant thresholds are met.

    The draft bill proposes reporting obligations based on employer size. Enterprises with 250 or more employees would report annually, while enterprises with 100 to 249 employees would report every three years. Enterprises with fewer than 100 employees would not be subject to reporting and joint pay assessment obligations. However, the obligation to provide criteria for pay increases would apply without a size threshold, irrespective of the possibility for an exemption for employers with fewer than 50 employees provided for in the directive.

    The draft bill does not introduce a new standalone sanctions regime for breaches of the pay transparency requirements. Instead, existing sanctions under the Protection Against Discrimination Act would apply including fines and financial sanctions where discrimination, non-compliance with statutory obligations or failure to comply with a Commission or court decision is established.

    The position should be treated as draft and pending, rather than final, until the bill is adopted and published.

    What should employers be doing now?

    Employers should continue preparing for implementation on the basis of the published draft, while recognising that the final law may change. Preparatory steps should include reviewing pay structures, documenting objective and gender neutral pay setting and pay progression criteria, assessing whether existing job architecture supports comparisons of the same work or work of equal value, improving HR data systems and testing the organisation's ability to calculate and explain gender pay gaps.

    Employers should also review recruitment practices to ensure that information on remuneration can be provided to candidates and that requests for candidates' previous remuneration are avoided. They should prepare processes for employee pay information requests, annual communications about those rights, pay transparency reporting, and potential engagement with the Protection Against Discrimination Commission or trade unions where individual pay confidentiality concerns arise.

  • Croatia

    Information for Croatia last updated in July 2026

    Legislative update

    No draft legislation yet.

    Level of change expected

    High change.

    Change expected

    Croatia currently has no specific pay transparency laws in place.

    Draft proposals for implementing the directive have not yet been published and it is unclear when their release might be expected.

    What should employers be doing now?

    Croatian employers should begin reviewing their pay structures, data systems and HR processes in anticipation of the directive. Employers should also monitor legislative developments closely to prepare for new reporting and transparency obligations once draft laws are released.

  • Cyprus

    Information for Cyprus last updated in July 2026

    Legislative update

    Public consultation on draft legislation closed on 4 December 2025. Two submissions were received. Cyprus' Department of Labour Relations published a consultation results table together with a revised final version of the draft law. The e-consultation process is formally completed. Parliamentary adoption remains anticipated during 2026.

    Level of change expected

    Medium/High change.

    Change expected

    The government of Cyprus is actively transposing the EU Pay Transparency Directive. The National Gender Equality Strategy 2024-26 confirms that implementation is underway, and a detailed draft law was published for public consultation in November 2025. This draft, which is aimed at strengthening equal pay enforcement through wage transparency, will introduce substantial new employer obligations, including enhanced pay transparency duties, data reporting requirements and stricter equal pay enforcement mechanisms.

    Once finalised in 2026, the law will reshape Cyprus’s existing legal and institutional framework on equal pay, requiring employers to adjust their practices to comply with a much more robust transparency regime.

    What should employers be doing now?

    Employers should start reviewing pay practices and data systems now and monitor the draft law closely, as major new transparency and reporting duties are expected once the directive is fully implemented.

  • Czech Republic

    Information for Czech Republic last updated in February 2026.

    Legislative update

    No draft legislation as of yet.

    Level of change expected

    Medium change.

    Change expected

    No draft bill has been published. A ban on pay secrecy clauses, effective 1 June 2025, has been adopted as a partial step. Full transposition is expected closer to June 2026.

    In the Czech Republic, the directive’s new requirements are largely anticipated by the existing Action Plan for Equal Pay for Women and Men, which sets out concrete steps to address inequalities. The directive will be implemented through amendments to the Labour Code. Some government parties have indicated they favour a minimalist transposition by introducing only the minimum changes required. It has not been clarified what this will look like in practice.

    What should employers be doing now?

    Czech employers should start reviewing pay practices and data processes now to ensure alignment with the Action Plan and upcoming Labour Code amendments, while monitoring developments closely given the possibility of a minimalist, but still unclear, transposition of the directive.

  • Denmark

    Information for Denmark last updated in July 2026.

    Legislative update

    Draft legislation published, consultation ongoing.

    Level of change expected

    Medium change.

    Change expected

    Main changes are to come from the expanded reporting duties under the directive. Danish employers already have some pay equality obligations, but the directive will require more detailed gender pay gap reporting, greater pay transparency and stronger employee rights to access pay information than currently required.

    The Danish Ministry of Employment has now issued a draft act to implement the directive into Danish law for external consultation. This consultation is the first step in the implementation process. The Ministry has invited affected associations, organisations and other stakeholders to submit written comments on the draft before an act is introduced in the Danish parliament.

    The consultation closed on 27 March, but the act has still not been introduced. Expectations are that the Danish parliament will be presented with the act in October 2026.

    What should employers be doing now?

    Employers should stress‑test current reporting processes against the draft legislation and identify likely gaps.

  • Estonia

    Information for Estonia last updated in July 2026.

    Legislative update

    No draft legislation as of yet.

    Level of change expected

    High change.

    Change expected

    Estonia's implementation law was adopted on 17 June 2026 and will become effective around mid-July 2026.

    What should employers be doing now?

    Employers in Estonia should start organising their pay data and ensure objective, gender neutral pay criteria in line with the published legislation.

  • Finland

    Information for Finland last updated in July 2026.

    Legislative update

    Legislation is currently being drafted.

    Level of change expected

    Medium change.

    Change expected

    The current Finnish government has stated that its intention is that the national implementation will not exceed the minimum level set by the directive. Legislation to implement the directive is currently being drafted, and the government proposal is scheduled for July 2026.

    What should employers be doing now?

    Employers should start reviewing their pay data, criteria and transparency practices now so they can promptly work towards the directive’s minimum requirements once the draft law appears in July 2026.

  • France

    Information for France last updated in July 2026.

    Legislative update

    Draft legislation has been published.

    Level of change expected

    Medium change.

    Change expected

    France has not met the 7 June 2026 deadline for transposition of the EU Pay Transparency Directive. On 6 March, the Ministry of Labour presented a first draft of the bill to employee and employer representative trade unions, followed by a further consultation on 19 March which resulted in amendments to the initial text. A revised version of the draft bill, dated 4 June 2026, has since been prepared and was submitted to the 'Conseil d'Etat' - the Supreme Administrative Court - on 5 June. Following the opinion of the Conseil d'Etat, the bill will be submitted to the Council of Ministers before being tabled in the French parliament.

    The labour minister aims to have the bill passed by the end of the year, with entry into force scheduled for 1 January 2028.

    The bill includes several substantial changes to French labour law, including:

    • a complete overhaul of the existing gender equality index, to be replaced by seven new indicators applicable to companies employing at least 50 employees. Employers employing at least 250 employees would be required to report these indicators annually. The 7th indicator - gender pay gap by category - would be reported every three years by companies employing between 50 and 249 employees, and annually by companies employing 250 employees or more. A collective bargaining agreement may exempt companies employing between 50 and 99 employees from reporting this indicator
    • a prohibition on contractual clauses preventing employees from disclosing their remuneration
    • a prohibition on employers requesting candidates' salary history, whether relating to their current employment or previous positions
    • the establishment of an employee's right to information regarding their compensation level as well as the average compensation for their job category
    • the obligation to indicate a compensation range and the applicable collective bargaining provisions in all job postings - if not published, this information must be provided in writing before or during the interview process
    • a complete reversal of the burden of proof in the event of the employer's failure to comply with the new transparency obligations (disclosures, employee right to information, salary ranges in job offers, communication regarding compensation components).

    The bill also provides for an administrative sanctions regime including:

    • penalties up to 1% of the total payroll for non-compliance with the new indicators
    • fixed administrative fines of up to €450, particularly in the event of failure to respond to requests for information
    • entry into force of the new obligations

    The effective date of these new obligations will be set by decree and will take effect no later than one year following the enactment of the law.

    Two specific exemptions to the effective date apply. For companies with between 50 and 149 employees, the obligation to report the 7th indicator on the gender pay gap by employee category would take effect on a separate date set by decree and no later than 1 June 2030. Compared with the March draft, which provided for a single 1 June 2030 deadline for all companies in this range, the revised version now introduced a differentiated implementation timeline:

    • no later than three years after enactment of the law for companies employing between 100 and 149 employees;
    • no later than six years after the law is enacted for companies employing between 50 and 99 employees.

    The employee right to information regarding their pay levels would take effect as of the date of entry into force of the collective bargaining agreement or the employer's unilateral decision establishing the categorisation of employees performing work of equal value, and no later than the date to be set by decree. The initial draft bill provided for a deadline of one year following the enactment of the law.

    What should employers be doing now?

    Employers should review their pay and HR policies against the published draft bill and begin preparing for the proposed new transparency obligations. In particular, they should assess their readiness for the revised gender equality indicators, salary range disclosure in recruitment, restrictions on salary history questions and pay secrecy clauses, employee pay information rights, and the proposed sanctions regime.

    Employers should also continue monitoring the legislative process including the Conseil d'Etat opinion, Council of Ministers review and parliamentary timetable so that they can adapt promptly once the final law and implementing decrees are confirmed.

  • Germany

    Information for Germany last updated in February 2026.

    Legislative update

    Draft legislation is expected imminently.

    Level of change expected

    Medium change.

    Change expected

    Germany expects to make adjustments under the directive, though the current framework is anticipated to remain largely compatible. The key changes introduced by the directive will include modifications to the recruitment process, expanded information rights for employees, new reporting obligations and the requirement for joint pay assessment with employee representatives. The commission established to ensure the effective and unbureaucratic implementation of the directive has recommended that the presumption of adequacy in section 4(5) EntgTranspG should continue to apply, meaning that employers bound by collective agreements may continue using collectively agreed pay grades unless an employee proves that the classification conflicts with article 4(4) of the directive. A draft law based on the commission's November 2025 final report is expected imminently.

    What should employers be doing now?

    Employers should begin reviewing their overall pay transparency processes to ensure they are clear, consistent and well documented, and prepare for more structured employee information request procedures. They should also monitor the upcoming draft legislation, which is expected to follow the commission’s recommendations closely.

  • Greece

    Information for Greece last updated in July 2026.

    Legislative update

    Greece has transposed the EU Pay Transparency Directive into law. The main obligations enter into force on 1 November 2026.

    Level of change expected

    Medium/High change.

    Change expected

    Greece has already implemented key EU equality directives through existing anti‑discrimination laws, but further updates will be needed to meet the more extensive reporting and transparency requirements of the directive.

    Once implemented, employers can expect new obligations aligned with the directive, such as providing pay ranges in job ads, greater access to pay information for employees, enhanced reporting duties for larger employers and stronger protections against discrimination and retaliation.

    What should employers be doing now?

    Employers should continue reviewing their pay transparency and equality practices, ensure they can provide clear pay information when required and closely monitor the committee’s forthcoming report so they are aligned with the new obligations arising under the directive.

  • Hungary

    Information for Hungary last updated in July 2026.

    Legislative update

    No draft legislation as of yet.

    Level of change expected

    Medium/High change.

    Change expected

    Hungary already has equal treatment and anti‑discrimination rules in place, but it currently lacks the types of reporting and transparency obligations required under the directive. Legislative changes will therefore be needed. The implementation process is reportedly underway and expected to take place later this year, but no public updates or draft legislation have been released, and the status of the transposition remains unclear.

    What should employers be doing now?

    Employers in Hungary should start reviewing their pay equity and data collection processes, identify any gaps in the information they would need for future reporting and closely monitor the developing legislation so they can adapt quickly once the implementation framework becomes public.

  • Ireland

    Information for Ireland last updated in June 2026

    Legislative update

    On 9 June, Ireland's equality minister confirmed that the remaining provisions of the directive will be introduced on a phased basis in national legislation. Ireland had formally notified the European Commission that transposition would not be complete by the 7 June 2026 deadline.

    On questioning in national parliament, two factors were cited by the minister as to why Ireland missed the deadline: EU Commission workshops on transposition were not completed until late September 2025, and the EIGE/European Commission toolkit was not published until the end of March 2026.

    Level of change expected

    Medium change.

    Change expected

    Ireland is preparing new pay transparency rules that will change how employers advertise and discuss pay. Under the proposed Equality (Miscellaneous Provisions) Bill 2024, employers will need to state salary levels or ranges upfront, in job ads or before interviews, and will be prohibited from asking candidates about their pay history. The Irish government has confirmed that legislation to implement the directive is currently being drafted.

    Ireland's Department of Children, Disability and Equality is commissioning a dedicated Irish Employer Gender Neutral Job Evaluation toolkit based on the EIGE framework, with employer training workshops to follow. No timeline for publication has been confirmed.

    What should employers be doing now?

    Employers should start reviewing recruitment materials and interview practices now to ensure they can share salary ranges upfront and remove any questions about pay history. Updating policies and training hiring managers early will make compliance with the new Irish rules much easier once they take effect.

  • Italy

    Information for Italy last updated in June 2026.

    Legislative update

    Italy has enacted implementing legislation. Legislative Decree No. 96 of 7 May 2026 was published in the Official Gazette on 1 June 2026 and entered into force on 7 June, transposing the directive into Italian law.

    Level of change

    Medium change.

    Changes implemented

    The Italian legislation introduces a comprehensive pay transparency framework applying to all public and private employers. It covers the full employment life cycle, from pre-hiring, to internal pay criteria management and periodic gender pay gap reporting for employers with at least 100 employees. For employers with at least 100 employees, where the gender pay gap exceeds 5% in any worker category, a joint review with trade unions is triggered.

    The most significant provisions include:

    • pre-employment transparency (article 5) - applies to all employers immediately. Job postings must state the salary or salary band. Selection processes must be gender neutral, and requesting candidates' pay history is prohibited
    • internal transparency (art. 6) - employers must make pay criteria and progression criteria accessible to employees. Employers with fewer than 50 employees are exempt from disclosing pay progression criteria
    • right to information (art. 7) - employees may request average pay data by gender for comparable roles once per year and employers must respond within two months. Clauses restricting employees from disclosing their own pay are void
    • gender pay gap reporting (art. 9) - applies to employers with 100+ employees. Reporting frequency varies by size: annual for employers with 250+ employees, with the first reports due on 7 June 2027; every three years for employers with 150-249 employees, with the first reports due on 7 June 2027; and every three years for employers with 100-149 employees, with the first reports due on 7 June 2031. Employers with fewer than 100 employees are exempt.
    • joint pay assessment (art. 10) - where the gender pay gap reaches or exceeds 5% in any worker category and cannot be objectively justified or corrected within six months, employers subject to reporting obligations must conduct a joint review with worker representatives
    • enforcement and sanctions (art. 41 Code of Equal Opportunities) - workers may invoke equal opportunities protections. Sanctions include potential revocation of public grants or subsidies.
    What should employers be doing now?

    Pre-employment obligations are now in force, with effect from 1 June 2026. Employers must immediately update job postings to include a salary or salary band, ensure gender neutral selection procedures and stop requesting candidates' pay history. Employers should also review internal pay structures for objectivity and gender neutrality and establish a process to handle employee pay information requests within the two-month statutory deadline. Employers with 150+ employees should begin collecting gender pay gap data now to meet the first reporting deadline of 7 June 2027.

  • Latvia

    Information for Latvia last updated in July 2026.

    Legislative update

    Draft legislation published.

    Level of change expected

    High change.

    Change expected

    Latvia currently has no dedicated pay transparency regime. Its draft EU Pay Transparency Directive implementation legislation is currently at the adoption stage, with the first draft published on 26 March 2026. However, that draft law has not yet been adopted. Implementation is delayed, with no confirmed timeframe.

    What should employers be doing now?

    Employers in Latvia should start organising their pay data and ensure objective, gender‑neutral pay criteria in line with the published draft legislation.

  • Lithuania

    Information for Lithuania last updated in July 2026.

    Legislative update

    Draft legislation has been published.

    Level of change expected

    Medium/High change.

    What change is expected?

    Lithuania is already partially aligned with the EU Pay Transparency Directive, as salary disclosure in job ads and transparent remuneration policies have long been required.

    The Lithuanian parliament adopted amendments to the Labour Code related to the implementation of the directive on 21 May 2026. Although the amendments formally entered into force on 7 June, some of the new requirements will only become mandatory from 2027.

    The Ministry of Social Security and Labour is expected to adopt secondary legislation related to data reporting to Sodra, the country's mandatory social security scheme, by 31 July 2026.

    What should employers be doing now?

    Employers should tighten remuneration policies, stop asking for salary history information and prepare systems for monthly gender pay gap reporting and 5% gap remediation duties ahead of the upcoming legislative changes.

  • Luxembourg

    Information for Luxembourg last updated in February 2026

    Legislative update

    Draft legislation is expected imminently.

    Level of change expected

    Medium change.

    Change required

    Luxembourg already has strong gender equality and anti‑discrimination laws, and its overall gender pay gap is very low. However, the EU Pay Transparency Directive will introduce additional obligations, particularly new reporting and hiring‑stage transparency requirements that go beyond current national practice. Employers should expect administrative and procedural changes, with a draft bill anticipated by the end of March 2026.

    What should employers be doing now?

    Luxembourg employers should review hiring and pay‑setting practices for transparency, prepare for new reporting obligations and monitor the draft bill due by the end of 2025 so they can adjust quickly once the rules are published.

  • Malta

    Information for Malta last updated in July 2026.

    Legislative update

    Malta fully implemented the EU Pay Transparency Directive on 5 June 2026 by means of the Equal Pay (Transparency and Reporting) Regulations 2026. These provisions came into force on the same date.

    Level of change expected

    Medium/High change.

    Change expected

    Maltese law already upholds equal pay for work of equal value, but the directive has introduced major new obligations. These include giving applicants initial pay information, banning salary‑history questions, requiring transparent pay and progression criteria, granting employees access to pay‑level information and introducing gender pay gap reporting. The directive also extends the limitation period for pay inequality claims.

    Additionally, since 27 June 2025, Malta has already introduced two similar rights: applicants may request pay information before employment begins; and employees may request individual and comparator pay level information in writing.

    What should employers be doing now?

    Employers should review and update pay structures for transparency, stop asking for salary history information and prepare to meet new reporting and pay information obligations for applicants and employees.

  • Netherlands

    Information for The Netherlands last updated in June 2026.

    Legislative update

    Draft legislation published (implementation date has been delayed).

    Level of change expected

    High change.

    Change expected

    The Netherlands is preparing for significant changes under the EU Pay Transparency Directive. A draft legislative proposal was open for public consultation until 7 May 2025, followed by an advisory opinion from the Council for the Judiciary on 4 June 2025, which supported the proposal but recommended amendments. The Ministry of Social Affairs and Employment has confirmed that the 7 June 2026 implementation deadline will not be met, with new legislation now expected to enter into force on 1 January 2027. Although delayed, the eventual changes will be wide‑ranging.

    What should employers be doing now?

    Employers should start reviewing pay and hiring practices for transparency, prepare their pay data for future reporting duties and closely track the delayed legislation so they can adjust ahead of the new 1 January 2027 implementation date.

  • Poland

    Information for Poland last updated in July 2026.

    Legislative update

    Partial implementation and a further draft bill has been published.

    Level of change expected

    Medium change.

    Change expected

    Poland already guarantees equal pay for the same or equivalent work, but major changes are expected as the EU Pay Transparency Directive has not yet been fully implemented. Key elements of the directive – such as reporting duties and expanded employee information rights – are still missing from Polish law, meaning the directive will have a significant impact on Polish pay structures once fully adopted.

    A partial implementation relating to recruitment transparency took effect on 24 December 2025, introducing obligations such as providing initial pay ranges, banning salary history questions, ensuring non‑discriminatory recruitment, applying gender‑neutral selection criteria and requiring gender‑neutral job ads and titles.

    Poland did not meet the implementation deadline of 7 June 2026. A revised draft bill dated 29 April 2026 is currently making its way through the legislative process. Compared to an earlier draft of 12 December 2025, the provisions have been clarified and amended in those areas that raised the most serious concerns.

    Under the current proposal, the remaining provisions are expected to enter into force six months after publication of the final act.

    What should employers be doing now?

    Employers should review their pay structures and recruitment practices for transparency, ensure clear, gender‑neutral criteria are in place and start organising pay data so they can meet upcoming reporting and employee‑information duties once the directive is fully implemented.

  • Portugal

    Information for Portugal last updated in February 2026

    Legislative update

    No draft legislation yet.

    Level of change expected

    Medium/High change.

    Change expected

    Portugal has not yet begun transposing the EU Pay Transparency Directive into national law. No draft legislation or official government communications have been issued to date. Progress is anticipated after the presidential elections in early February 2026, at which point legislative activity may begin.

    What should employers be doing now?

    Employers in Portugal should review their pay and hiring practices for transparency, start organising reliable pay data and monitor developments after the February 2026 elections so they can respond quickly once draft legislation is introduced.

  • Romania

    Information for Romania last updated in July 2026.

    Legislative update

    Draft legislation is expected imminently.

    Level of change expected

    High change.

    Change expected

    Romania is expected to make significant updates to its employment laws to meet the requirements of the EU Pay Transparency Directive. Although existing rules already prohibit gender‑based pay discrimination, the directive will introduce much clearer and more practical obligations for employers. These include sharing salary ranges during recruitment, banning salary history questions, being transparent about how pay and progression decisions are made, removing or significantly restricting pay secrecy clauses and reporting on gender pay gaps for organisations with 100 or more employees. Taken together, these changes will require Romanian employers to adopt a more open and structured approach to pay, marking a notable shift from Romania’s traditionally strict salary‑confidentiality rules.

    A draft bill is currently undergoing the parliamentary review process. It is expected to complete the Senate phase by the end of the October, with the decisive Chamber of Deputies vote expected by the end of the year at the earliest.

    The draft bill does not propose significant deviations from the text of the directive. However, it has just recently received a negative reasoned opinion from the Legislative Council setting out various technical and legal criticisms regarding the text. It is therefore likely that the final text of the law will undergo significant amendments.

    What should employers be doing now?

    Preparations to comply with the principles set out in the directive should not be postponed until the final version of the law is adopted. Compliance with the forthcoming pay transparency legislation is a long-term process which, from a legal perspective, should begin with an inventory of the company's existing position; updating job descriptions to accurately reflect employees' actual duties thereby facilitating comparisons between employees performing work of equal value; aligning job titles across organisational charts, employment contracts and job descriptions; establishing clear evaluation criteria and remuneration policies; documenting pay decisions; ensuring recruitment processes comply with the new requirements; developing the capacity to respond promptly to employee requests for information; and engaging in meaningful cooperation with social dialogue partners.

    For organisations employing at least 150 employees, the first mandatory gender pay gap reporting is expected to fall due in June 2027 in line with the directive, based on data relating to the 2026 calendar year.

  • Slovakia

    Information for Slovakia last updated in February 2026.

    Legislative update

    Draft legislation published.

    Level of change expected

    Medium/High change.

    Change expected

    Slovakia is preparing for substantial changes to its pay transparency framework as it moves to implement the EU Pay Transparency Directive. Although Slovak employers have been required since 2018 to include basic wage information in job advertisements, the directive will significantly expand these obligations and introduce new requirements across both labour and anti‑discrimination law. A dedicated Draft Act (the Draft Act on the Application of the Principle of Equal Pay for Men and Women for Equal Work or Work of Equal Value and on Amendments to Certain Acts) has now been published and is currently undergoing review by the advisory bodies of the government of the Slovak Republic before being submitted to parliament. The proposed legislation, expected to take effect on 1 June 2026, will mark a substantial amendment to Slovakia’s existing framework, bringing in broader salary‑transparency duties, enhanced employee information rights and strengthened mechanisms to ensure equal pay.

    What should employers be doing now?

    Slovak employers should start reviewing their pay and recruitment processes now so they are ready for the wider transparency obligations coming in 2026 and keep a close eye on the proposed legislation leading up to 1 June 2026.

  • Slovenia

    Information for Slovenia last updated in February 2026.

    Legislative update

    No draft legislation as of yet.

    Level of change expected

    High change.

    Change expected

    Slovenia has not yet transposed the EU Pay Transparency Directive into national legislation, meaning further changes are still expected. For now, the key domestic provision is found in the Employment Act (ZDR‑1), in force since 31 December 2023, which already requires “equal pay for equal work”.

    Once Slovenia begins the transposition process, employers can expect additional obligations beyond this existing principle, as the directive introduces significantly broader transparency and reporting requirements.

    What employers should be doing now?

    Employers should start reviewing their current pay‑setting practices and be ready to adapt once the directive is transposed, ensuring they can demonstrate compliance with the existing “equal pay for equal work” rule as a foundation for upcoming changes.

  • Spain

    Information for Spain last updated in February 2026.

    Legislative update

    Draft legislation is expected.

    Level of change expected

    Low/Medium change.

    Change expected

    Spain already has a robust equal pay framework in place, including pay registers, job evaluation within equality plans and remuneration audits, but the EU Pay Transparency Directive will require Spain to go further. The biggest changes will come in pre‑employment transparency, such as requiring salary ranges in job adverts and banning pay history questions, as well as introducing staged gender pay gap reporting aligned with EU thresholds. Spain has not yet published draft legislation, but it must complete transposition by 7 June 2026, meaning employers can expect additional transparency and reporting duties to be added to the existing system.

    What should employers be doing now?

    Employers should start reviewing their current pay data and equality measures, prepare to disclose salary ranges in job ads and ensure recruitment processes can function without pay history questions. They should also begin assessing their systems and job evaluation frameworks so they are ready for staged gender pay gap reporting once Spain transposes the directive.

  • Sweden

    Information for Sweden last updated in July 2026.

    Legislative update

    Draft legislation has been published; implementation under reconsideration.

    Level of change expected

    Low/Medium change.

    Change expected

    Sweden expressed that it wanted to delay the June 2026 transposition deadline and reopen negotiations at EU level. While supporting the directive's aim of tackling unjustified pay gaps, the government said there are significant practical difficulties in fitting it into the Swedish labour market model - concerns strongly shared by employers and trade unions. Sweden therefore called for a "fresh start" on the legislation. However, the European Commission has stated that it does not envisage including the directive in any future omnibus regulatory package or taking 'stop the clock' measures, as it considers the directive essential for the full realisation of the right to equal pay between men and women.

    Following the Commission's announcement, Sweden is expected to resume its legislative process, according to several analysists. However, final implementation into Swedish law is not expected to happen until 2027 at the earliest.

    What should employers be doing now?

    The EU Pay Transparency Directive entered into force on 7 June 2026 and, although the Swedish government has not yet implemented it into Swedish law, certain provisions may still be applicable to public sector employers due to those provisions having direct effect. Since the directive has not yet been implemented Sweden's Equality Ombudsman, which is the authority responsible for ensuring compliance, has a limited mandate to investigate individual cases related to the directive. However, as it has the authority to investigate cases involving discrimination and pay, an individual who believes that their rights regarding equal pay have not been respected may still file a complaint.

    EU directives have no direct effect in the private sector, so these employers will not face any new obligations until Swedish law has been brought into line with the directive. However, all employers should continue reviewing their pay structures, gather reliable pay data and prepare for clearer salary‑setting processes.

Pinsent Masons' global Pay Equity Solution allows us to calculate your pay gaps, assess equal pay risks and develop targeted action plans and associated comms in line with applicable legal frameworks internationally. Find out more, and make an enquiry.

We are processing your request. \n Thank you for your patience. An error occurred. This could be due to inactivity on the page - please try again.