EU Pay Transparency Directive: implementation across EU member states

Information for Austria last updated in February 2026

Legislative update

No draft legislation yet.

Level of change expected

Medium/High change.

Change expected

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.

Information for Belgium last updated in February 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 has adopted a decree covering certain public institutions, and the Flemish government has prepared a similar draft. No draft legislation exists yet for the private sector.

The public sector decree largely mirrors the directive and leaves job evaluation systems to each institution. Although it currently applies only to certain public bodies, it is likely indicative of how Belgium will implement the directive more broadly.

What should employers be doing now?

Employers should start reviewing pay practices, strengthen data systems and monitor upcoming legislation, as the public sector decree is likely to shape wider national implementation.

Information for Bulgaria last updated in February 2026

Legislative update

No draft legislation yet.

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 legislation. However, Bulgaria will still need to implement additional measures introduced by the directive, meaning further alignment and new employer obligations are expected.

On 12 February 2025, the Council of Ministers adopted a decision to create an action plan for 2025 that includes measures resulting from Bulgaria's EU membership. This decision outlines plans for the transposition of the directive, with a deadline of 29 May 2026 for the adoption of the new legislation by the Bulgarian parliament.

What should employers be doing now?

Employers should start reviewing pay structures and strengthening data systems now, as new transparency and reporting duties are expected. With transposition underway and a May 2026 deadline set, employers should monitor developments closely and prepare for additional equal pay obligations.

Information for Croatia last updated in February 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 and must introduce new legislation to transpose the directive by June 2026.

According to the plan of advisory activities set out by the Croatian Ministry of Labour, Pension System, Family and Social Policy, implementation of the directive is expected in spring 2026 through amendments to several existing legislative acts, most notably the Labour Act.

Draft proposals of the implementing legislation are expected to be published by the end of March.

What should employers be doing now?

Croatian employers should begin reviewing their pay structures, data systems and HR processes in anticipation of the directive, as Croatia currently has no domestic rules and must implement the directive by June 2026. Employers should also monitor legislative developments closely to prepare for new reporting and transparency obligations once draft laws are released.

Information for Cyprus last updated in February 2026

Legislative update

Draft legislation published (consultation ongoing).

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.

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.

Information for Denmark last updated in February 2026.

Legislative update

No draft legislation as of yet.

Level of change expected

Medium change.

Change expected

Main changes are expected 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.

What should employers be doing now?

Employers should stress‑test current reporting processes against directive requirements and identify likely gaps.

Information for Estonia last updated in February 2026.

Legislative update

No draft legislation as of yet.

Level of change expected

High change.

Change expected

As there are currently no national laws or specific requirements in place, major pay transparency changes are expected.

What should employers be doing now?

With no local legislation yet in place and changes expected, employers should begin basic preparation, for example by reviewing pay structures from an equality perspective and monitoring forthcoming legislative updates.

Information for Finland last updated in February 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 March 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 March 2026.

Information for France last updated in February 2026.

Legislative update

Draft legislation is expected imminently.

Level of change expected

Medium change.

Change expected

France does not expect major changes because its 2018 Professional Equality Index already requires annual gender‑equality reporting for employers with 50+ employees. However, further legislation is expected to allow France to align fully with the directive.

The French government has not yet presented a draft bill, and consultations with employee and employer representative trade unions are ongoing. A meeting was held on 15 January 2026, and a second meeting scheduled for 29 January 2026 was subsequently postponed, with no new date announced. It appears increasingly likely that France will not meet the transposition deadline of 7 June 2026 set by the directive, and the French Minister of Labour has indicated that the draft bill should be submitted to parliament “before the summer”.

Future proposals include banning questions about previous salary, requiring salary ranges in job adverts, giving employees annual written notice of their right to request pay information and requiring employers to provide pay calculation criteria and job evaluation methods. Confidentiality clauses preventing employees from disclosing pay would be prohibited. The Professional Equality Index would be revised to align with the directive’s seven indicators, and the burden of proof in pay discrimination claims would shift to employers.

What should employers be doing now?

Employers should start reviewing their current pay and HR policies to identify any areas where greater transparency may be needed. They should also ensure their processes and documentation are robust and begin monitoring upcoming legislative developments so they can adapt quickly once the draft bill is released.

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.

Information for Greece last updated in February 2026.

Legislative update

No draft legislation as of yet.

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 EU Pay Transparency Directive’s more extensive reporting and transparency requirements.

The directive has not yet been transposed, and no draft law or consultation paper has been published. A specialist committee is currently preparing the national framework and is expected to deliver its report by 28 February 2026, ahead of the 7 June 2026 transposition deadline.

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 start 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 can prepare for the new obligations expected under the directive.

Information for Hungary last updated in February 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, 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.

Information for Ireland last updated in February 2026

Legislative update

There has been partial implementation as the government has published the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 which covers pre‑employment pay transparency. However, the broader pay transparency bill is still in preparation and is currently being drafted.

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.

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.

Information for Italy last updated in February 2026.

Legislative update

Draft legislation has been published.

Level of change expected

Medium change.

Change expected

Italian legislation is already partially compliant with the new EU provisions, given that Law No. 162/2021 on equal pay (amending the so‑called "Code of equal opportunities between men and women") already includes some of the provisions contained in the new directive. However, the directive includes a number of provisions, in particular concerning the right of information and rights of protection, which will have to be transposed in Italy.

On 5 February 2026, Italy published draft legislation to implement the directive. Although it is still subject to ministerial review, the draft already confirms key obligations including mandatory pre‑employment pay transparency and also includes a proposal for the types of workers who should be covered.

What should employers be doing now?

Employers should start reviewing their recruitment and pay practices to ensure they are transparent, objective and gender neutral. They should also monitor the development of the draft legislation, so they are ready to adjust their processes once final requirements are confirmed.

Information for Latvia last updated in February 2026.

Legislative update

No draft legislation as of yet.

Level of change expected

High change.

Change expected

Latvia currently has no dedicated pay transparency regime. Draft amendments are expected in 2026 which are likely to introduce significant new employer obligations.

What should employers be doing now?

Employers in Latvia should start organising their pay data, ensure objective, gender‑neutral pay criteria and monitor the Ministry of Welfare’s upcoming draft amendments.

Information for Lithuania last updated in February 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. However, significant new obligations are coming, with draft legislation introduced in 2025 that will tighten remuneration policy rules, ban salary history questions, introduce monthly pay gap reporting, require action where the gap exceeds 5% and remove salary data from confidentiality clauses. These amendments are currently progressing through the Tripartite Committee process and will further strengthen pay transparency and equal pay compliance once adopted.

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.

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.

Information for Malta last updated in February 2026.

Legislative update

Partial – published legal notice 112 of 2025 which has introduced some rights, but further legislation is expected.

Level of change expected

Medium/High change.

Change expected

Maltese law already upholds equal pay for work of equal value, but the EU Pay Transparency Directive will introduce 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 will also extend 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.

Further legislation is expected to be published ahead of 7 June 2026.

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.

Information for The Netherlands last updated in February 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.

Information for Poland last updated in February 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.

Full implementation is expected before June 2026, and a draft bill published on 12 December 2025 is in early legislative stages.

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.

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.

Information for Romania last updated in February 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 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.

The Romanian government is in the final stages of preparing a draft, and the draft bill is expected to be published any day now, after which it will be released for public consultation.

What should employers be doing now?

Employers should begin reviewing pay structures and recruitment materials and prepare for gender pay gap reporting, ensuring they can disclose salary ranges and operate without pay secrecy clauses.

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.

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.

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.

Information for Sweden last updated in February 2026.

Legislative update

Draft legislation has been published.

Level of change expected

Low/Medium change.

Change expected

Sweden is preparing to update its existing salary‑reporting framework, but most of the current system is expected to remain unchanged. What employers should plan for, however, are additional transparency and reporting obligations. These include greater detail around how salaries are set and clearer information for employees and unions on pay policies and pay structures. A draft proposal outlining these changes was presented to the government in July 2024 and has since been through public consultation. The government is expected to put forward formal legislation in March 2026, which would introduce these new requirements once adopted.

What should employers be doing now?

Employers should begin reviewing their pay structures, gathering reliable pay data and preparing for clearer salary‑setting processes to meet the upcoming transparency requirements. Taking early steps now will make it easier to comply once the new legislation is introduced.