EU Pay Transparency Directive: complete legislation guide and FAQs

The EU Pay Transparency Directive will be implemented across Europe by 7 June 2026, making pay transparency the norm in order to shine a light on the causes of pay equity and push employers to close the gender pay gap.

For many companies, major changes will be necessary to align with the new legislation, including:

• Compliance with stricter gender pay gap reporting
• Transparency on salaries and progression pathways for employees
• Transparency on the salary band for all new roles advertised.

We know this is a big cause for concern for People Teams – suddenly there’s a whole new set of regulations to be the company expert on, and pay transparency plans need to turn into action much more quickly than originally thought.

That’s why we’ve put together this guide, which covers:

1. FAQs: key questions answered on the EU Pay Transparency Directive
2. A summary of the Directive itself
3. Transposition tracker: how EU member states are implementing the Directive into their national legislation

Firstly, let's tackle all the most frequently asked questions about the new EU Pay Transparency Directive.

What is the EU Pay Transparency Directive?

The EU Pay Transparency Directive is a new piece of legislation introduced by the European Council to increase transparency about pay for employees throughout the EU. 

It represents a significant change in employment law on pay transparency and pay equity.

The use of the term ‘directive’ means that this set of rules are fairly top level and represent a consistent goal or framework which EU countries must achieve – but it’s up to individual countries to determine and implement their own laws to reach those goals.

That’s as opposed to a ‘regulation’ set by the EU which would mean that the rules are binding legislation and must be rolled out exactly as stated across the impacted member states.

There are therefore differences in how the 27 EU member states are implementing the new rules. See the transposition tracker below for more details.

Where can I read the full text of the EU Pay Transparency Directive?

To read the EU Pay Transparency Directive in full, go to the EUR-Lex website, where all EU legal publications are housed.

Why the focus on pay transparency in the EU Pay Transparency Directive?

The central purpose of the EU Pay Transparency Directive is to close the gender pay gap in the EU, ensuring that men and women receive equal pay for equal work.

Research has shown strong evidence that pay transparency is currently lacking and that introducing pay transparency laws is a major factor in closing the gender pay gap. 

This is because without transparency about pay, it’s impossible for employers and employees to be aware when differences in salary are occurring that could be a result of discrimination – especially because a lot of the time it comes as a result of unconscious bias. Without awareness about pay discrimination, it’s also impossible to challenge and address those differences.

And there’s still a long way to go to close the gender pay gap in Europe, which is why the EU Pay Transparency Directive is such an important piece of legislation.

In fact, research from Ravio's pay equity report shows that women are still paid 25% less than men across the entire European tech industry when we don’t consider any external factors (the unadjusted gender pay gap). Even when we adjust this data to control for workers in the same job function, job level, and country, women are still paid 2.5% less than men.

What is pay transparency?

Pay transparency refers to companies openly and honestly sharing their compensation approach with both current and prospective employees.

The core aim is to improve pay equity by making it possible for employees to identify when they may be a victim of pay discrimination due to gender. Pay transparency also has additional positive benefits on employee engagement because of the increased understanding of pay practices and fairness.

Different companies will take different actions to improve pay transparency, but some of the key elements include:

• Including the salary range for a new role within the job description or advert
• Openly and clearly communicating key compensation practices to employees, such as the company’s compensation philosophy, job levels, salary band structure, compensation review process, and so on.
• Disclosing employee salaries – most companies will only disclose the salary band for each job role and level, but some companies are going further to fully disclose all salaries, such as Buffer.

Why is pay transparency important?

Pay transparency has a vital role to play in reducing pay discrimination and closing the gender pay gap.

Research shows that there is a strong link between a lack of transparency about pay practices and a large gender pay gap. 

This is because without transparency about pay, employers and employees aren’t always aware when differences in salary are occurring that could be arising as a result of discrimination – especially because a lot of the time it comes as a result of unconscious bias. Without awareness about pay discrimination it’s impossible to challenge and address those differences.

Because increased transparency about pay brings the causes of pay discrimination to light, it results in an improved assessment of differences in pay between genders – and a more accurate adjusted gender pay gap calculation (the adjusted pay gap being a calculation that takes into account factors like job level or location which contribute to pay differences). 

Pay transparency can also be a great way to improve employee engagement and increase retention. Increasing employee understanding of how compensation works in the company builds their trust in the company and reduces feelings of unfairness in pay.

What is the difference between the adjusted gender pay gap and the unadjusted gender pay gap? 

There are two ways to calculate the gender pay gap when we assess pay equity, which are broken down below. 

• Unadjusted pay gap: The unadjusted pay gap refers to the raw difference in median earnings between men and women, without accounting for any factors such as job level, job function, or the country they perform their work in. It provides a straightforward comparison but does not reflect differences in job roles or other relevant factors.
• Adjusted pay gap: The adjusted pay gap takes into account factors that contribute to pay differences between men and women, including job function, job level, and country. ‘Adjusting’ the raw data to account for these helps us paint a like-for-like comparison, which helps to answer the question of whether men and women are receiving equal pay for equal work. Because there are so many factors which impact pay discrimination towards women, the adjusted gender pay gap can be a more valuable metric to help companies identify where pay discrepancies are coming from.

Who does the EU Pay Transparency Directive apply to?

The EU Pay Transparency Directive applies to all public and private sector employers in the European Union.

There will be a staggered rollout, with large companies impacted first:

• Employers with 150 or more employees will need to submit gender pay gap reporting in June 2027, reporting on the calendar year of 2026
• Employers with less than 150 employees will need to submit gender pay gap reporting in June 2031, reporting on the calendar year of 2030.

The gender pay gap reporting requirements also vary depending on company size, as follows:

• Companies with more than 250 employees will be required to report annually
• Companies with 100-249 employees will be required to report every three years
• Companies with less than 100 employees will not be required to report (though individual EU member states could choose to change this during implementation).

The EU Pay Transparency Directive has also been deemed relevant to those countries are are not EU member states but do participate in the European Economic Area (EEA) – Iceland, Liechtenstein, and Norway. The Directive must first be formally incorporated into the EEA Agreement, and then these countries will also transpose it into national law.

When will the EU Pay Transparency Directive be in force?

The EU Pay Transparency Directive is already in force and has been since 6 June 2023 – meaning it has been official EU legislation since that date.

However, individual EU member states have three years to implement the legislation within their own national laws, by 7 June 2026. It’s possible some will transpose the Directive into local law more quickly than this – some countries have also indicated delays. See the transposition tracker below for more detail.

There will be a staggered rollout of gender pay gap reporting requirements, with the first deadlines as follows:

• Employers with 150 or more employees will need to submit gender pay gap reporting in June 2027, reporting on the calendar year of 2026
• Employers with less than 150 employees will need to submit gender pay gap reporting in June 2031, reporting on the calendar year of 2030.

Does the EU Pay Transparency Directive apply to UK companies?

The UK is no longer an EU member state following Brexit, and so is not directly impacted by the EU Pay Transparency Directive.

However, if a company is registered in the UK (or anywhere else non-EU) but has more than 100 employees based in EU member states, they will need to comply with the legislation and reporting requirements for that location.

The EU Pay Transparency Directive rulings also go above and beyond existing pay transparency and gender pay gap reporting legislation in the UK, and so UK employers may find that they need to align with the rulings anyway to remain competitive as the wider talent market trends towards pay transparency.

On 21 May 2024 the UK government paused its pay transparency pilot for job applicants. This was a pilot looking at how to enforce salary ranges for all new job positions and banning employers from asking candidates about salary history – both important rulings within the EU Pay Transparency Directive. At first glance this seems to suggest that the UK may fall behind the EU on pay transparency laws. However, the language of the announcement suggests that they may simply be waiting to see how the roll out of the EU Pay Transparency Directive goes first:

Given this, we should expect to see changes to UK pay transparency laws during or after the roll out of the EU Pay Transparency Directive in 2026 and beyond.

Does the EU Pay Transparency Directive apply to contractors or freelancers?

No, the EU Pay Transparency Directive does not apply to contractors or freelancers.

The wording used is that the Directive “applies to all workers who have an employment contract or employment relationship as defined by law” which excludes contractors.

How does the EU Pay Transparency Directive differ to existing pay transparency legislation across Europe?

The EU Pay Transparency Directive introduces much stricter rules on pay transparency practices and gender pay gap reporting to all EU member states. 

The exact impact will differ from country to country depending on their current pay transparency legislation – and we won’t know the full impacts until each EU member state announces how they intend to transpose the Directive into local law.

France, for instance, already mandates gender pay gap reporting for all employers with 50+ employees and makes the results of this public via their Gender Equality Index. Germany, on the other hand, has less rigorous pay transparency laws currently with only employers with 500+ employees required to report on equal pay.

What changes are required for employers under the EU Pay Transparency Directive?

Whilst it’s too early to know how each EU member state will implement the new legislation, there are four main areas of ruling covered by the EU Pay Transparency Directive which result in changes for employers:

1. Stricter gender pay gap reporting. Companies with over 100 employees will be required to submit gender pay gap reports. Any company with a gap of over 5% will be required to conduct a joint pay assessment alongside employee representatives to further analyse the gender pay gap and put an action plan in place to close it.
2. Employee rights to pay information. Employees will be entitled to request information about the company’s compensation approach, particularly: job levels, salary bands, career progression, pay progression. Employees will also be entitled to request information about the pay of colleagues who perform equal work or work of equal value to them. 
3. The burden of proof shifts to the employer. The employer will need to prove that pay discrimination has not taken place in the case of complaint – whereas historically the employee would have to prove that pay discrimination has taken place. 
4. Increased access to pay information for job applicants. Employers will be required to disclose the salary range for all new roles to candidates before interviews. Employers will be banned from asking candidates about their salary history. 

For a comprehensive overview of what’s included in the EU Pay Transparency Directive, head to Part 2 of this article (after the FAQs).

What needs to be included in gender pay gap reporting under the EU Pay Transparency Directive?

The gender pay gap reporting must include:

• Mean and median gender pay gap for base salary
• Proportion of men and women receiving variable pay
• Mean and median gender pay gap for variable pay
• Proportion of men and women in quartile pay bands i.e. lower pay, lower middle, middle upper, upper.

What is a joint pay assessment in the EU Pay Transparency Directive?

Article 10 of the EU Pay Transparency Directive rules that any employer which identifies a gender pay gap of over 5% in any category included in the reporting requirements and:

• cannot justify that gender pay gap through objective, gender neutral explanations
• does not rectify the gap in average pay within six months of submitting the report

… must then conduct a joint pay assessment.

The joint pay assessment is further analysis of the gender pay gap data, including identifying the root causes of gender pay differences and measures to address them. This assessment must be conducted in cooperation with employee representatives, and must be made available to all employees once complete.

Is salary confidential by law in the EU?

The EU Pay Transparency Directive will make it illegal for employers in the European Union to include confidentiality clauses (also known as pay secrecy clauses) in employee contracts. 

This means it is illegal to try and stop employees from discussing their salary – employees have a right to discuss pay with their colleagues in order to identify any potential pay discrimination issues.

How should employers be preparing for the EU Pay Transparency Directive?

The EU Pay Transparency will be fully in place in 2026 (with first reporting in 2027) which will come around fast. It’s therefore important for employers to start preparing now – assessing what changes will need to be made within the company to comply with the legislation, and making a plan to implement those changes.

To help make the transition nice and smooth, we’ve put together:

• Guide: walking you through all the key steps employers need to take to prepare
• Checklist: pay transparency checklist tool to work through your own process as a company (free download).

What are the key changes the EU Pay Transparency Directive will mean for employers?

There are four main areas of ruling covered by the EU Pay Transparency Directive which result in changes for employers:

1. Stricter gender pay gap reporting. Companies with over 100 employees will be required to submit reports on their gender pay gap for every category of workers who performs equal work or work of equal value, and any company with a gender pay gap of over 5% will be required to conduct a joint pay assessment in cooperation with employee representatives to further analyse the gender pay gap and take action to reduce it. Read more about gender pay gap reporting under the EU Pay Transparency Directive.
2. Increased access to pay information for employees. Employees will be entitled to request information on pay levels and the criteria for career and pay progression. Read more about the rulings on worker rights to pay information within the EU Pay Transparency Directive.
3. The burden of proof shifts to the employer. In any case regarding pay discrimination, the employer will need to prove that pay discrimination has not taken place – whereas historically the employee would have to prove that pay discrimination has taken place. Read more about enforcing ruling and potential penalties within the EU Pay Transparency Directive.
4. Increased access to pay information for job applicants. Employers will be required to include the salary range for all job positions to candidates before interviews. Employers will be banned from asking candidates about their salary history. Read more about the rulings for job applicants within the EU Pay Transparency Directive.

For a more comprehensive overview of what’s included in the EU Pay Transparency Directive, head to Part 2 (after the FAQs).

The FAQs above cover the basics, but to be the company expert on the EU Pay Transparency Directive you need to get stuck into the text of the Directive itself. 

Unfortunately, as you might expect, it’s a long, dense document full of legal language, which makes it tricky to read and digest. 

To help you out we’ve read through the full document ourselves and in this section you’ll find a full summary of the text includes – chapter by chapter, article by article.

Chapter 1 of the EU Pay Transparency Directive: purpose, scope, key concepts

Chapter 1 covers all the context for the conditions under which the EU Pay Transparency Directive applies:

• Article 1 explains the purpose of the Directive is to ‘strengthen the application of the principle of equal pay between men and women… through pay transparency.’
• Article 2 sets the scope of the Directive as applying to all employers across public and private sectors, and to all workers with an employment relationship.
• Article 3 defines key concepts used within the Directive, importantly including defining that ‘pay’ refers both to base salary and other cash or non-cash compensation received from an employer for work completed.
• Article 4 establishes the need for EU member states to put in place tools or methodologies for objectively assessing the relative value of work performed within a company in order to be able to determine what ‘equal work or work of equal value’ means – as this is core to the Directive, which aims to ensure that men and women receive equal pay for equal work or work of equal value.

Chapter 2 of the EU Pay Transparency Directive: pay transparency rules

Chapter 2 contains the rules on pay transparency for employers – of the whole Directive, this is the chapter that’s really worth reading in detail. 

The articles covered are:

• Article 5 covers pay transparency prior to employment, with two key rulings that applicants must receive the salary range of a new job position before interview and employers must not ask about an applicant’s salary history during the hiring process.
• Article 6 covers pay and progression transparency for existing employees, ruling that employers must make gender neutral criteria for pay levels and career progression ‘easily accessible’ to employees.
• Article 7 covers employee rights to pay information, ruling that employees have the right to receive information on pay levels for employees doing equal work or work of equal value to them – and that employers must make employees aware of this right annually. It also rules that employees cannot be prevented from discussing salaries.
• Article 8 rules that employers must make any information shared relating to articles 5, 6, 7 accessible for employees with disabilities.
• Article 9 explains the gender pay gap reporting requirements introduced by the Directive, including how often reporting must be conducted and in what format (a ‘user-friendly way on its website or otherwise publicly available). It also highlights that employees have the right to request further information on explanations for gender pay gaps identified.
• Article 10 rules that any employer with a gender pay gap over 5% must also conduct a ‘joint pay assessment’ with employee representatives including further analysis on the gender pay gaps identified and measures to address differences in pay across men and women. The joint pay assessment must also be made available to all employees.
• Article 11 rules that EU member states must provide ‘technical assistance and training’ to all employers with less than 250 employees to help them comply with reporting requirements.
• Article 12 covers data protection for the reporting, which must be in line with GDPR.
• Article 13 establishes that EU member states should ensure ‘social dialogue’ as they roll out the Directive in national law. Social dialogue is a key concept in EU law which simply means that ‘social partners’ i.e. employers and workers organisations must be consulted.

Chapter 3 of the EU Pay Transparency Directive: enforcement and penalties

Chapter 3 establishes how EU member states should enforce the rulings within the EU Pay Transparency Directive.

There’s a lot of articles in this Chapter and the nuance will be better understood once individual countries implement the legislation in their national law, so we won’t dive into every single detail until this is in place – but let’s take a look at some of the key inclusions:

• Legal cases against pay discrimination. Official court procedures will be available to employees to enforce their right to equal pay (Article 14) and employees who have been discriminated against will have a legal right to compensation which must include ‘full recovery of back pay and related bonuses or payments in kind, compensation for lost opportunities and moral prejudice’ (Article 16).
• Burden of proof shifts to the employer. The ‘burden of proof’ in pay discrimination cases shifts from employee to employer i.e. the employer will have to prove that pay discrimination has not taken place for a case to be dropped (Article 18).
• Penalties. EU member states must implement ‘effective, proportionate and dissuasive’ penalties for companies who do not comply with the legislation on pay transparency (Article 23). What these penalties are is open to interpretation, but we'd expect substantial financial penalties to be on the table.

Chapter 4 of the EU Pay Transparency Directive: horizontal provisions

Chapter 4 of the EU Pay Transparency Directive covers horizontal provisions. 

This refers to the ‘horizontal direct effect’ in EU law, which means that citizens of EU member states can rely on EU law against other citizens within a national court – as opposed to an EU court (this is vertical direct effect). 

So, in essence, this final chapter covers all the rules that make sure that EU member states can effectively transpose the Directive into national law.

Like with chapter 3, therefore, much of the text applies only at a country-level and so the implications won’t be clear until we see individual EU member states start to make changes, but here are some of the important highlights:

• EU member states can choose to introduce legislation which goes above and beyond the Directive in favour of workers – but cannot use it to reduce the level of worker protection in any area (Article 27)
• EU member states must establish a monitoring body responsible for tasks such as raising awareness about pay transparency and the right to equal pay and publishing insights on the data gathered through gender pay gap reporting (Article 29)
• EU member states must bring the rulings into force in national law by 7 June 2026 (Article 34).

Last updated: 12th March 2026

EU member states have until 7 June 2026 to transpose the EU Pay Transparency Directive into their own national laws.

The Directive represents mandatory rulings that all EU member states must introduce by this time, but individual countries could choose to implement those rulings in different ways, so it’s important to understand local laws as they are determined.

So far, the following EU member states have made announcements on their transposition of the EU Pay Transparency Directive into national laws:

Let’s take a closer look at each member state that has started the transposition process.

Belgium – Wallonia-Brussels Federation: EU Pay Transparency Directive decree

The Wallonia-Brussels Federation is located within Belgium, but has its own separate government. In November 2024 they passed a decree for transposing the EU Pay Transparency Directive into national law – which will come into effect in June 2026.

The decree applies to all companies within the Federation which covers: companies created by the Federation, educational institutions within the Federation, and government institutions within the Federation’s control. 

The decree largely follows the rulings of the Directive, with a few key differences and additions:

• Timing for salary range disclosure during hiring. The Federation’s decree specifies that employers must disclose the salary range and any relevant collective agreement provisions for new roles as soon as they are advertised i.e. within the job advert itself – the Directive only specifies that candidates must have this information before interviews.
• Parental leave disclosure. The Federation’s decree adds to the Directive’s reporting requirements by mandating that employers must also report on the amount of leave granted to male and female workers for family responsibilities (maternity, paternity, parental, adoption) and the equivalent in pay.
• Penalties for non-compliance. The decree rules that employers who fail to comply with the requirements or fail to reduce their pay gaps to an acceptable level will be fined up to 3,900 euros per year or the equivalent of the actual damages suffered.

Poland: EU Pay Transparency Directive partial transposition

Poland became the first EU member state to enact the EU Pay Transparency Directive with an Act to amend Poland’s Labour Code which was formally enacted and signed by the President in June 2025 – and included legislation on pay equality. 

The Act will take effect on December 24, 2025 – six months before the EU's transposition deadline.

However, Poland's transposition is partial only. The amendment covers:

• Job applicant pay transparency requirements: salary ranges in job advertisements, gender-neutral language, and prohibition on asking about salary history.

But does not include:

• Gender pay gap reporting requirements
• Existing employee pay transparency requirements – information on pay structures, the right to request pay equity information. 

A more comprehensive draft proposal was previously submitted by a group of Poland's Parliament Members, which included plans to go beyond the Directive's rulings with a requirement for employers to provide equal pay information to employees within 14 days of request, and proposed fines of 1,000-30,000 zloty for non-compliance. In February 2025, the Sejm (Poland's parliament) voted against this initial proposal.

Now, the Polish government has indicated that comprehensive legislation addressing the remaining Directive requirements – particularly gender pay gap reporting obligations – will follow by the end of 2025. The first gender pay gap reports under the Directive aren’t due until June 2027, so this phased approach may be common across other countries. 

Malta: EU Pay Transparency Directive partial transposition

Malta published Legal Notice 112 of 2025 on June 27 2025, legislation to amend its existing Transparent and Predictable Working Conditions Regulations to align with the requirements of the EU Pay Transparency Directive.

Legal Notice 112 took effect on August 27 2025, and so is now national law. 

However, the legislation currently only includes some of the rulings on job applicant and employee pay transparency – with gender pay gap reporting requirements not yet accounted for, and so further legislation will be needed in Malta.

Malta’s legislation varies from the EU Directive in a couple of key ways:

• The salary range for a job posting must be provided to applicants ‘before the start of employment’ – giving employers more flexibility on timing, compared to many countries which are specifying that this information must be included in the job advert or during interviews.
• No ban on asking job candidates about their salary history is included in the legislation – a requirement of the Directive.

Italy: EU Pay Transparency Directive draft proposal published

On 5 February 2026, Italy's Council of Ministers gave preliminary approval to a draft legislative decree implementing the EU Pay Transparency Directive. 

The draft was submitted to parliamentary committees with a deadline of 18 March 2026 to provide an opinion, after which it returns to the Council of Ministers for final adoption.

Italy is expected to meet the June 2026 transposition deadline.

The current draft closely follows the Directive, but there are a few notable national specificities:

• National collective bargaining agreements as the primary reference for equal work. Italy anchors the assessment of "equal work" and "work of equal value" to the classification and grading systems in national collective bargaining agreements (NCBAs) – the existing framework through which pay is primarily determined in Italy. Employers not covered by an NCBA must use the agreement signed by the most representative trade unions in their sector. Employers may supplement this with their own job classification systems, provided these are objective and gender neutral. 
• Pay ranges mandatory in job adverts. The draft requires salary information to be included in job postings and vacancy notices – a stricter requirement than the Directive, which only mandates that this information be provided before interview.
• Proactive publication option for pay information requests. Rather than responding individually to each employee request for pay information, employers with 100+ employees may choose to publish average pay data by gender and worker category proactively on their intranet or a restricted area of their website.
• Group-level pay gap reporting. Where a unified group pay policy is in place, employers may aggregate gender pay gap data at national level rather than reporting entity by entity.
• No shift in burden of proof. Despite the Directive requiring that the burden of proof in pay discrimination cases shifts to the employer, this is not reflected in the current draft – a notable omission that may still be addressed before final adoption.
• No criminal sanctions. Enforcement relies on administrative sanctions under the existing Equal Opportunities Code, with no criminal penalties introduced.

Cyprus: EU Pay Transparency Directive draft proposal published

Cyprus published an initial draft bill implementing the EU Pay Transparency Directive in November 2025, followed by an updated version on 26 January 2026. 

The government is aiming for full transposition by the June 2026 deadline.

Cyprus goes meaningfully beyond the minimum requirements of the Directive in several areas, making it one of the more demanding implementations seen so far:

• Explicit weighting of job evaluation criteria. The draft requires employers not only to use objective, gender neutral criteria when assessing work of equal value (skills, effort, responsibility, working conditions) but also to document how those criteria were weighted – and to agree those weightings jointly with employee representatives where they exist. 
• Four year retrospective data on request. Upon request, employers must provide gender pay gap data for up to four previous years – potentially reaching back to 2022, as the draft includes no clause limiting the lookback to the implementation date. 
• Criminal liability for directors and officers. Non-compliance can result in fines of up to €10,000 and/or imprisonment of up to six months. Notably, directors and officers may be held personally criminally liable unless they can prove the offence occurred without their consent, connivance or negligence.
• Broad definition of pay. The draft adopts a wide definition of pay covering all cash and in-kind benefits received directly or indirectly, including variable elements – though it excludes termination-related payments and employee pension contributions.

Slovakia: EU Pay Transparency Directive draft proposal

Slovakia's Ministry of Labour, Social Affairs and Family published a preliminary legislative notice in May 2025, with the draft law published in September 2025. 

Rather than amending existing legislation, their proposal introduces a new Act on the ‘Application of the Principle of Equal Pay for Men and Women for Equal Work or Work of Equal Value’, alongside amendments to the existing Labour Code, Labour Inspection Act, and Employment Services Act.

The draft entered public consultation from 19 September to 9 October 2025, with Cabinet approval expected in October and Parliamentary adoption to follow. The new Act is scheduled to enter into force on 1 June 2026, meeting the EU deadline.

The draft closely follows the language of the EU Directive, but with some notable differences:

• Job applicant salary range transparency: Slovakia’s proposal requires pay ranges must be shared with candidates before compensation negotiations commence – the EU Directive doesn’t specify the exact timing, only that it must be before they are hired.
• Pay structures and job categorisation: Slovakia provides clarity on how jobs must be categorised for ‘work of equal value’ by specifying that soft skills (interpersonal, social, communication) can be applied as a sub-factor within four main assessment criteria: skills, effort, responsibility, and working conditions. The draft also provides examples of legitimate pay differences, including qualifications, professional experience, job performance, or other objective factors unrelated to gender.
• Employee pay transparency: Employers have two months to respond to employee requests for information about the pay level for peers performing equal work to them. Where providing information could reveal individual identity, details must be shared only with workers' representatives or the equality body.
• Gender pay gap reporting: After the first gender pay gap reporting deadline (June 2027 or 2031, due to the official start date of the EU Directive on 6 June 2026), subsequent reporting deadlines will be 31 March in Slovakia.
• Penalties for non-compliance: Administrative fines up to €4,000 for non-compliance with gender pay gap reporting obligations. Employees have three years to make compensation claims based on pay inequity.

Germany: EU Pay Transparency Directive draft proposal in progress

Germany set up an independent expert commission to consult on recommendations for implementing the EU Pay Transparency Directive into national law, and they submitted their final report to Germany's Federal Minister for Gender Equality on 7 November 2025. 

The German government is now preparing a draft bill based on these recommendations, expected ahead of the 7 June 2026 deadline.

The Commission's core mandate was to implement the Directive "with a minimum of bureaucracy." 

Notably, the report reveals significant disagreements between employers' associations and employee representatives on key issues – particularly around the treatment of collective agreements and the scope of reporting obligations – which will need to be resolved in the draft legislation.

Key distinctive features of Germany's proposed approach:

• Six-person minimum comparison group: For data protection reasons, a minimum of six persons of the opposite sex in each ‘group of employees doing equal work or work of equal value’ is recommended, though there are doubts whether this fully meets the Directive's requirements. Where group sizes are too small, information would be provided only to workers' representatives or the equality body.
• Preferential treatment for employers with collective agreements: Employers bound by collective agreements would face reduced scrutiny and obligations. Their collective agreements would be presumed compliant ("presumption of adequacy"), and when employees request pay information, employers would initially only need to provide comparisons within the collective agreement's pay scale groups – a narrower scope than required for other employers. Employees would need to prove the collective agreement doesn't meet gender-neutral criteria to access broader comparison data.
• Separate reporting for tariff and non-tariff employees: Companies would, therefore, report separately for employees covered by collective agreements and those not covered.
• Works councils as workers' representatives: The competent works council would be recognised as the workers' representatives for all Directive requirements, including determining job evaluation criteria, forming worker categories, and conducting joint pay assessments. However, in companies bound by collective agreements that meet the Directive's criteria, works councils would not have participation rights in determining job evaluation criteria.
• Actual vs target remuneration: The Commission recommends that actual remuneration (not target remuneration) should be the basis for reporting obligations, though this was not unanimous.
• Flexibility on variable pay components: Companies can choose whether to group variable pay components, rather than itemising each component separately.
• Limited employee right to information: Employees can request information once per year about the previous calendar year, receiving only total gross remuneration (annual and hourly) without breakdown into individual components.
• Minimising bureaucracy: Integration with existing digital infrastructure for employer reporting, harmonisation with CSRD reporting requirements, voluntary digital tools and templates provided by the government, and text form documentation (no "wet ink" signatures required). 

Finland: EU Pay Transparency Directive draft proposal in progress

Finland's Ministry of Social Affairs and Health published a draft bill on May 16, 2025 to implement the EU Pay Transparency Directive. The proposal is subject to consultation, with the official government proposal expected to be published in December 2025.

The current draft proposal is very closely aligned with the EU Directive on all elements: pay transparency for job applicants, pay transparency for employees, and gender pay gap reporting requirements.

Lithuania: EU Pay Transparency Directive draft proposal in progress

Lithuania published their draft proposal for transposing the EU Pay Transparency Directive in August 2025 – now in consultation, and expected to be in place before the June 6 2026 deadline.

Lithuania already has strong pay transparency foundations in place, and so several elements of the Directive are already in place in national law, including:

• Salary ranges for job postings
• Establish pay structures in collaboration with employee representatives – applicable to all companies, with companies of 50+ employees required to include their process for salary increases.
• Gender pay gap reporting – employers are required to submit monthly pay data to the State Social Insurance System (SoDRA) which publishes total average pay gaps.

The draft proposal builds upon this to align with the Directive’s requirements on providing employees with information on equal pay for colleagues who perform equal work, as well as requirements to reduce the gender pay gap to under 5%.

Lithuania’s draft proposal does define the penalties for non-compliance, with fines of €400 minimum to €6,000 maximum for employers who fail to comply. The proposal also removes their current cap (six months of pay) on employee compensation for pay discrimination cases.

Interestingly, Lithuania’s proposal includes definitions for ‘same work’ (roles where work is similar enough that employees could be interchanged with no significant cost) and ‘equal work’ (roles with comparative importance to the employer’s objectives – enabling cross-functional analysis). The definition of ‘equal work or work of equal value’ is an area that many employers are struggling with, so this explicit distinction within the legislation is important. 

Norway: EU Pay Transparency Directive implementation via EEA Agreement

Norway is not an EU member state, but participates in the European Economic Area (EEA). The EU Pay Transparency Directive has been designated as EEA-relevant and will be incorporated into the EEA Agreement, after which Norway will transpose it into national law.

Key distinctive features of Norway's expected approach:

• No fixed implementation deadline. Unlike EU member states (which must transpose by 7 June 2026), Norway's timeline depends on when the Directive is formally incorporated into the EEA Agreement. The Ministry of Culture and Equality initiated implementation work in November 2025. While no formal deadline exists, implementation is anticipated within 12-24 months of the Directive's incorporation into the EEA Agreement.
• Building on strong existing foundations. Norway's Equality and Anti-Discrimination Act already requires biennial gender pay reviews for private sector employers with 50+ employees, including analysis of parental leave impact on pay progression. Implementation will likely focus on adding new requirements (salary ranges in job postings, standardised reporting format, salary history ban) while strengthening existing provisions.
• Expected alignment with Swedish approach. Norway is likely to adopt a similar implementation approach to Sweden, given both countries' similar labour market models, strong traditions of gender equality legislation, and emphasis on collective bargaining and social partnership.

Read more about pay transparency in Norway →

Netherlands: EU Pay Transparency Directive draft proposal – but transposition delayed beyond EU deadline

The Netherlands was among the first EU member states to publish draft implementing legislation, releasing an initial proposal in March 2025 and an amended proposal in January 2026 – which is now with the Council of State for advice.

The Ministry of Social Affairs and Employment subsequently confirmed that the June 2026 transposition deadline will not be met, with implementation now targeted for 1 January 2027, meaning that pay gap reporting would begin in June 2028 (a year later than required by the Directive). 

The European Commission has pushed back on the delay. On 18 December 2025 it formally confirmed that it expects all member states to implement by June 2026, warning that failure to do so may trigger infringement proceedings. 

So far, the Dutch proposal closely follows the Directive's requirements and avoids additional national obligations. That said, there are a few features worth noting:

• Works council involvement throughout. Works councils (mandatory for all Dutch companies with 50+ employees) are the primary vehicle for worker representation under the proposal, including in pay assessments and corrective measures. However, the January 2026 amended proposal adjusted this role: the works council must be consulted on the accuracy of pay gap reporting, but is no longer required to confirm accuracy – responsibility for that sits with the management board.
• Salary range disclosure before negotiations. The proposal requires salary information to be provided before salary negotiations commence, but does not require it to be included in the job posting itself – aligned with the Directive, but a less strict approach than several other member states are proposing.

Sweden: EU Pay Transparency Directive draft proposal published – but transposition delayed beyond EU deadline

The Swedish government released their initial draft proposal for implementing the EU Pay Transparency Directive in May 2024: ‘Genomförande av lönetransparensdirektivet’.

On 15 January 2026 a draft proposal was referred to the Council on Legislation (Lagrådet) – the final step before being brought to the parliament for debate.

The original intention was for the legislation to be in force on 1 July 2026; however, on 11 March 2026 the government announced a delay to 1 January 2027, with the first salary reports to the Discrimination Ombudsman (DO) moved to no later than 20 May 2028. The delay followed pressure from employer organisations who stated the original dates posed significant challenges.

Sweden's draft proposal differs from the minimum requirements of the EU Pay Transparency Directive in a few key ways:

• Written salary mapping threshold raised to 25 employees. Sweden's existing Discrimination Act mandates salary mapping for all employers (with written documentation required for those with 25+ employees), whereas the Directive's formal reporting requirements only apply to employers with 100+ employees.
• Extended limitation period for discrimination claims. Employees have three years to bring discrimination claims related to pay equity, compared to shorter periods in many other jurisdictions.
• Direct union access to legal proceedings. Trade unions can bring discrimination claims directly to the Labour Court without going through the Discrimination Ombudsman (DO) first.
• Employers with a pay gap of more than 5% in any reported category must submit their report to the DO, who will collect the data and publicly present aggregated results.
• Penalty fees for non-compliance. Employers who fail to submit their salary report to the DO or meet information obligations to job applicants and employees will face penalty fees.

The proposal is also tailored to align with employment law and local working culture in Sweden:

• Collective agreement provisions must be disclosed. Alongside the salary range, employers must disclose applicable collective agreement provisions to job applicants before salary negotiations begin.
• Employee representatives can facilitate information requests. Employees can exercise their right to equal pay information via employee representatives (mandatory in all companies with 25+ employees) rather than requesting directly from their employer.
• Accessible formats for employees with disabilities. Information on pay structures and equal pay data must be provided in accessible formats for employees with disabilities.

Read more about pay transparency in Sweden →

France: EU Pay Transparency Directive draft proposal published – but transposition delayed beyond EU deadline

France began consultations with labour unions and employers' federations in May 2025 to transpose the EU Pay Transparency Directive. 

On 6 March 2026, the government sent social partners a pre-draft bill (highlights below). A final consultation meeting on the draft bill is scheduled for 19 March 2026, after which the bill will face parliamentary scrutiny, expected in autumn 2026.

This means that France will miss the June 2026 transposition deadline. The French Minister of Labour has indicated the draft bill should be submitted to parliament "before the summer", with the law expected to pass by September 2026.

Below are the key highlights from the draft bill: 

• Definition of work of equal value. The proposed criteria for assessing work of equal value include six factors: professional knowledge, experience-based skills, responsibilities, physical or mental effort, non-technical (soft) skills, and working conditions.
• Reporting threshold lowered to 50+ employees. The Directive sets the threshold at 100+ employees, but France's existing Égalité Professionnelle Index already applies to employers with 50+ employees, and the draft maintains this lower threshold.
• Seven new pay transparency indicators. The current Gender Equality Index would be replaced by seven new indicators, most of which would be published publicly by the Ministry of Labour.
• Expanded role for the CSE throughout the process. The CSE (Comité Social et Économique – the mandatory employee representative body in all French companies with 11+ employees) must be involved at multiple stages: employers with 100+ employees must formally consult the CSE on the results of all seven indicators and transmit any CSE opinion to the authorities, the CSE and trade unions can request full explanations for any pay gap identified (even below 5%), and where a gap above the 5% threshold cannot be justified or remedied, the CSE must be consulted at each stage of the corrective process.
• Significant financial penalties. Fines of up to 1% of payroll for non-compliance, rising to 2% for repeat breaches within five years, plus fixed penalties of €450 per breach for certain information failures.
• Pay ranges mandatory in job adverts. France’s draft requires salary ranges to appear in job postings, whereas the Directive only requires this information to be provided before interview.

Ireland: EU Pay Transparency Directive draft proposal  – but transposition delayed beyond EU deadline

In January 2025 the Irish government published 'General Scheme of the Equality (Miscellaneous Provisions) Bill 2024' – a partial transposition covering pay transparency requirements for job candidates and employees, but not gender pay gap reporting. 

Pre-legislative scrutiny on the bill completed in October 2025, and the Department of Equality is currently considering the recommendations.

A separate general scheme covering the remaining elements of the Directive (including gender pay gap reporting) is currently being developed, but has not yet been published.

The Department of Equality has confirmed that Ireland will miss the June 2026 transposition deadline. Implementation will proceed on a "phased basis", and employers will not be penalised for not having all elements of the Directive in place by June 2026.

A few features of Ireland's approach are worth noting:

• Pay ranges required in job adverts. Ireland's proposal specifies that employers must disclose the salary range within the job posting itself – going further than the Directive, which only requires this information to be provided before interview.
• Ireland's existing Gender Pay Gap Information Act 2021 already covers some elements of the Directive, and the reporting threshold dropped from 150+ to 50+ employees from June 2025 – meaning many employers already have gender pay gap reporting experience to build on.

Denmark: EU Pay Transparency Directive draft proposal published – but transposition delayed beyond EU deadline

On 26 February 2026, Denmark published a draft bill implementing the EU Pay Transparency Directive for public consultation, with responses due by 27 March 2026. The bill would amend the existing Danish Equal Pay Act.

Importantly, the current timeline means that Denmark will not meet the June 2026 transposition deadline, with the legislation expected to enter into force on 1 January 2027.

The draft closely follows the Directive in many respects, but has several notable national specificities:

• Reporting threshold extended to 50+ employees. The Directive requires reporting only for employers with 100+ employees, but Denmark's draft extends this to employers with 50-99 employees where there are at least eight employees of each gender in the same job category. 
• Government-generated pay reports via Danmarks Statistik. Denmark intends to auto-generate pay reports using existing salary data already reported to Statistics Denmark, at no cost to employers. However, employers cannot rely solely on these reports – they may need to supplement them with their own data on categories of employees performing equal work, which is not currently captured by government systems. Responsibility for accuracy sits with the employer.
• Elected shop steward as worker representative. The draft designates an elected employee representative (the shop steward) as the partner for evaluating job categories and criteria – though notably, there is no requirement for a company to elect a representative if it has no existing legal obligation to do so.
• Explicit recognition of soft skills in defining equal value. The draft explicitly states that soft skills must not be underestimated in assessing work of equal value, naming collaboration, communication, social and emotional competencies, informal responsibilities, and knowledge sharing.
• Longer limitation period for employee tribunals. Employee claims made under the Danish bill would be subject to a five-year limitation period (with a six-month pause when an employee notifies the employer of a claim) – more favourable to employees than the Directive's three-year minimum.
• Government-defined response timeframe for employee requests. Where the Directive leaves response times for pay report clarifications as a "reasonable period", Denmark's draft defines this as two months.
• Delayed reporting timeline. First pay gap reports for employers with 150+ employees are due by 1 September 2028 – 15 months later than the Directive's June 2027 deadline.