Introduction
The deadline for transposing Directive (EU) 2023/970 into national law was 7 June 2026. By 13 October 2026, five Member States had adopted laws intended to transpose the whole Directive: Greece, Italy, Lithuania, Malta and Slovakia. Three had transposed part of it. The other 19 range from a bill before parliament to no published draft.
This article argues that, for employers operating in more than one Member State, the differences between the national texts matter more than the differences in timing. The texts already differ on how an employer must structure, classify, calculate, disclose and govern pay information. The article has three parts. The thematic section sets out the main differences. The country sections are a reference. The final section proposes an operating model for an employer in the five Member States with comprehensive transposing laws.
Main findings
A common job evaluation scheme can supply consistent evidence of the value of work. The legal categories used for comparison remain national, such as the CCNL classification in Italy and the job groups reported to Sodra in Lithuania.
Where the state calculates the indicators, as in Lithuania, errors in the data employers submit pass directly into the regulators’ figures.
Deadlines for answering requests for pay information range from eight days in Malta to two months. The rules on who receives information that could identify an individual also differ.
First reporting periods and the triggers for joint pay assessment differ between countries. Each needs to be tracked separately.
Several national laws give collective agreements a protected position. The Commission’s FAQ states that the Directive applies to pay set by collective bargaining.
How to read this article
Status. Each Member State is placed in one of five groups according to the furthest stage its published texts have reached. “Comprehensive transposing law adopted” means that a law intended to transpose the whole Directive has been passed. The label describes the legislative stage. Whether each provision meets the Directive is covered in each country section under “Gaps compared with the Directive”.
Gaps compared with the Directive. Where a national text provides less than the Directive, the country section lists it under this heading and names the Directive provision concerned. The heading also covers first reporting dates and periods that differ from Article 9. Start dates for other obligations are given in the status section of each country. Where the point depends on a commentator’s reading, the commentator is named.
Gold plating. Gold plating means a national rule that goes further than the Directive requires. Each country section separates two types. Additional requirements are national rules that are stricter than the Directive or add obligations it does not contain, such as Malta’s eight-day deadline for answering a request for pay information where the Directive allows up to two months. Permitted options are choices that the Directive itself offers to Member States, such as requiring pay reporting from employers with fewer than 100 employees (Article 9(5)). Each item is also marked as adopted (in a law passed to transpose the Directive), proposed (in a draft or bill) or existing rule (national law already in place before transposition). Choices that reduce an obligation, such as exempting employers with fewer than 50 workers from providing progression criteria (Article 6(2)), are recorded under what has been transposed.
Sources. The review draws on the Directive, national legislative portals, official gazettes, ministerial statements and law firm and specialist trackers. Each country section states the text analysed. Where the analysis relies on a published summary rather than the official text, the summary is named. Sources are listed at the end of the article under the same headings as the sections they support. Draft texts can change before adoption.
The position at a glance
Comprehensive transposing law adopted (5): Greece, Italy, Lithuania, Malta, Slovakia.
Partial transposing law adopted (3): Belgium (sub-national public sector staff only), Estonia (recruitment and pay secrecy), Poland (recruitment).
Bill at parliamentary stage (7): Bulgaria, Czechia, Denmark, Finland, France, Netherlands, Romania.
Government draft or proposal published (6): Cyprus, Ireland, Latvia, Portugal, Spain, Sweden. Ireland’s proposal covers two pre-employment measures only.
No government draft published (6): Austria, Croatia, Germany, Hungary, Luxembourg, Slovenia. Unpublished drafts are reported to exist in Austria, Croatia, Luxembourg and Slovenia.
The legislative stage says little on its own about the work an employer faces. Slovakia’s adopted law gave existing employers until 31 July 2026 to have compliant pay structures. Finland’s bill, still before parliament, routes reporting through the Incomes Register and relies on payroll data employers already file.
The European Commission has said it is not open to requests for more time. It published a set of frequently asked questions on the Directive on 6 August 2026. The Commission’s decisions of 15 July and 25 September 2026 on failures to notify transposition do not include this Directive.
What the national texts show
Collective agreements
The Commission’s FAQ of 6 August 2026 states that the Directive applies to all employers, including those whose pay is set through collective bargaining. Any pay difference between women and men doing the same work or work of equal value still has to be justified on objective, gender-neutral criteria.
Several national texts give collective agreements a protected position. Italy presumes conformity where an employer applies a national collective agreement (CCNL) signed by the comparatively most representative unions, without prejudice to proof of discriminatory individual pay treatment (Article 4(1) of the decree). Greece presumes there is no unjustified pay discrimination where a collective agreement sets pay on gender-neutral criteria. Malta deems collective agreements in force when its regulations took effect to be valid and compliant until they expire, with no recourse for terms agreed in them (regulation 23(6)). Germany’s 2017 Pay Transparency Act already presumes that pay rules in collective agreements are appropriate (section 4(5)). Its ministry has said it is still working on the nature and scope of a privilege for collectively agreed pay rules in the new law. How these provisions sit with the Commission’s reading may be tested in national courts or by the Commission.
State calculation of pay gap indicators
Article 9(8) of the Directive allows Member States to compile the first six indicators, points (a) to (f) of Article 9(1), from administrative data such as tax and social security filings. The seventh, the gap by category of workers, depends on the employer’s own categories. This explains a pattern in the national texts. Statistics Finland would compile six of the seven indicators from the Incomes Register. France’s labour minister said six of the seven French indicators would be automated. Czechia would use the existing unified monthly employer report, with employers adding pay gaps by category. Portugal’s draft has employers with 50 or more employees supply data to a designated entity that determines the indicators. The Dutch Council of State pointed out that reports can be largely prepared by a government body.
Lithuania goes further. The roles are split three ways. The employer submits data: each employee’s job group under its pay system, filed with the social insurance board Sodra, together with monthly pay and paid working time. Sodra calculates the indicators, including those by job group. Sodra then sends the results each month to the employer, the State Labour Inspectorate and the Equal Opportunities Ombudsperson. Sodra also publishes some of them. A worker’s category therefore becomes a field in a social insurance filing. A categorisation error reaches the regulators’ data before any internal report is prepared.
Job evaluation written into national law
Article 4(4) of the Directive names four criteria for assessing the value of work: skills, effort, responsibility and working conditions. Relevant soft skills must not be undervalued. National texts are writing their own versions into law.
Slovakia uses complexity, responsibility, strenuousness and working conditions, taking account of soft skills, in particular social and communication skills (section 3). Ministry guidance of 30 June 2026 recommends an analytical points method with a 1,000-point reference maximum.
Czechia’s bill uses complexity, responsibility, strenuousness and working conditions. Every employer would need a documented remuneration system that groups work of equal value.
Italy’s decree lists skills, responsibilities and working conditions without effort, the fourth criterion in the Directive (Article 4(3)). The CCNL classification is the reference for legal comparisons. An employer’s own evaluation system is allowed as a supplement to the CCNL (Article 4(4)).
Portugal’s draft requires the pay policy to weigh skills, responsibility and working conditions. Its definition of work of equal value refers to qualifications or experience, responsibilities, physical and mental effort and working conditions.
Malta requires the four Directive criteria, taking account of soft skills, agreed with employee representatives where they exist (regulation 3(3)).
Spain’s draft requires a score or numerical value for each job using analytical systems that meet standards of adequacy, completeness and objectivity.
A single grading framework can give consistent evidence of the value of work across these countries. It needs local mapping of factor definitions and evidence. Lewis Silkin notes that multinational methodologies may not adequately reflect working conditions as a statutory criterion under Slovak law. In Italy the CCNL classification remains the reference for legal comparisons.
Thresholds, deadlines and response times
Reporting below 100 employees, a permitted option under Article 9(5): France’s bill starts at 50 employees. Portugal’s draft starts at 50. Spain’s draft adds employers with 50 to 99 employees from 2031. Denmark’s consultation draft covers 50 to 99 employees where a job group has at least eight employees of each sex. Lithuania collects data from every employer.
Answering a request for pay information: the Directive allows up to two months (Article 7(4)). Malta requires a reply within eight days. Sorainen reads Lithuania’s amended Labour Code as requiring a reply within one month. Romania’s bill proposes 30 working days and Poland’s draft 30 days. Italy limits each worker to one request a year. Spain’s draft does the same unless circumstances change.
First reports: the Directive requires employers with 150 or more workers to report by 7 June 2027 on the previous calendar year (Article 9(2) and (3)). Greece and Slovakia keep the 7 June 2027 date but set a shorter first reference period by transitional rule: 1 November to 31 December 2026 in Greece and 1 August to 31 December 2026 in Slovakia. Czechia, the Netherlands and Denmark (on the consultation draft) would move first reports into 2028. In Lithuania, monthly data collection starts in January 2027 and Sodra’s first annual indicators are due from March 2028. The Swedish government said in March 2026 that it intended to propose first reports by 20 May 2028. Germany’s ministry has said reporting will first be due in June 2028.
Where a Member State has not transposed
A directive does not by itself impose obligations on private employers. After the deadline, a public sector employer can be bound by provisions of the Directive that are sufficiently precise and unconditional. National courts must interpret existing national law as far as possible in line with the Directive. The underlying right to equal pay comes from Article 157 TFEU. The Court of Justice has held that Article 157 can be relied on against private employers, including in claims based on work of equal value (Case C-624/19 Tesco Stores, 2021). The transparency obligations themselves, such as pay ranges, information requests, reporting and joint pay assessment, reach private employers only through national law.
Country by country
Austria
Current implementation status and timeline
Status: No government draft published.
On 6 June 2026, the day before the deadline, Labour Minister Korinna Schumann (SPÖ) sent her own draft into the government’s internal coordination after negotiations with the social partners failed to produce an agreed text. The coalition partners ÖVP and NEOS have not agreed to it. The ÖVP has reportedly said it wants agreement between employer and employee representatives first. NEOS and the Austrian Economic Chamber argue the draft would create excessive bureaucracy through gold plating. ORF reported in mid-September 2026 that there was still no agreement.
Why: the absence of a social partner agreement and disagreement within the governing coalition.
What has been transposed into legislation and draft legislation
Text analysed: none published. The content below is as reported by ORF.
Nothing has been transposed. ORF reports that the Minister’s draft would require companies with 100 or more employees to produce income reports.
Gold plating
Cannot be assessed until the draft is published. The 100-employee threshold reported by ORF matches the Directive.
Belgium
Current implementation status and timeline
Status: Partial transposing law adopted.
The partial transposition covers public sector staff of the Fédération Wallonie-Bruxelles and of Flanders. There is no federal draft. On 1 June 2026 the federal government formally asked the European Commission for a six-month postponement. Employment Minister David Clarinval also put around 30 questions of interpretation to the Commission. L&E Global considers adoption in late 2026 or early 2027 the most realistic scenario.
Why: Belgian transposition requires an opinion from the National Labour Council (NAR/CNT) before the federal government and parliament legislate. L&E Global reports that this process did not progress because the employer federation VBO-FEB opposed the Directive. Belgian commentary reports that the Council’s talks were paused at the employer side’s request pending more clarity at EU level or a draft bill. Transposition also requires changes to national collective agreements No. 25 (equal pay) and No. 38 (recruitment) and to the 2012 gender pay gap law.
What has been transposed into legislation and draft legislation
Text analysed: no federal draft. The sub-national measures are described from the Flemish Parliament record and L&E Global.
The Fédération Wallonie-Bruxelles adopted rules for its own staff. The Flemish Parliament adopted a decree on 10 June 2026 applying parts of the Directive to the Flemish public sector. It was ratified and promulgated on 12 June and published in the Belgian Official Gazette on 17 June 2026. Private sector employers are not yet covered by any Belgian transposing measure.
Gold plating
Cannot be assessed at federal level until a draft is published. L&E Global expects a minimal transposition.
Bulgaria
Current implementation status and timeline
Status: Bill at parliamentary stage.
The Council of Ministers submitted the bill to the National Assembly on 11 September 2026 after a public consultation from 19 May to 18 June 2026. It would take effect on promulgation. Reporting and joint pay assessment would apply from 7 June 2027 for employers with 150 or more employees and from 7 June 2031 for those with 100 to 149.
What has been transposed into legislation and draft legislation
Text analysed: the bill submitted on 11 September 2026, as summarised by CMS.
Nothing has been transposed. The bill amends the Protection Against Discrimination Act. The Commission for Protection against Discrimination is the central enforcement and monitoring body.
On promulgation all employers would have to use gender-neutral job titles and vacancy notices, give applicants the starting pay or its range, stop asking about pay history, answer requests for individual and average pay information, notify employees of that right by 31 January each year, make pay and progression criteria transparent and stop using confidentiality clauses that prevent the exercise of the right to equal pay.
The bill does not use the Article 6(2) option to exempt employers with fewer than 50 workers from providing progression criteria.
Gaps compared with the Directive
The bill has no standalone definition of pay. CMS notes that the terms it uses may be narrower than the Directive’s definition (Article 3(1)(a)).
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: the four criteria for work of equal value also govern individual pay increases. Article 6(1) of the Directive requires only that progression criteria be objective and gender-neutral. Stakeholders criticised the Bulgarian rule in consultation because performance, experience and market factors do not fit within the four criteria.
Croatia
Current implementation status and timeline
Status: No government draft published.
Minister Alen Ružić said in late May 2026 that amendments to the Labour Act were in the final phase before parliamentary procedure. A public consultation expected in June 2026 did not take place. Croatian trade press reports that a draft has since been sent to the social partners. The amendments are expected to take effect towards the end of 2026.
Why: the pay transparency changes are part of a wider Labour Act package that also covers the platform work directive and annual leave rules.
What has been transposed into legislation and draft legislation
Text analysed: none published. The content below is as reported in the Croatian press.
Nothing has been transposed. Reported content includes pay ranges in job advertisements, a right to information on pay and progression criteria and pay gap reporting for larger employers. The Ministry of Labour has published a voluntary job evaluation methodology with tools tailored to company size. Article 4(2) of the Directive requires Member States to make such tools available.
Gold plating
Cannot be assessed until the draft is published. If the reported requirement to put pay ranges in job advertisements is confirmed, it would be an additional requirement. Article 5(1) of the Directive gives a published vacancy notice as one of several ways to provide pay information.
Cyprus
Current implementation status and timeline
Status: Government draft or proposal published.
A draft law was published for consultation in November 2025 and a revised draft in late January 2026. Parliament was dissolved on 23 April 2026 ahead of elections on 24 May. On 6 September 2026 Labour Minister Marinos Mousiouttas said the bill was expected to go to the Council of Ministers in September and then to the House of Representatives. The Minister indicated that employers with 150 or more employees would first submit pay gap data in early June 2027.
Why: the parliamentary elections and the transition that followed.
What has been transposed into legislation and draft legislation
Text analysed: the published drafts of November 2025 and January 2026, as summarised by Trusaic and George Z. Georgiou & Associates.
Nothing has been transposed. The published drafts follow the Directive closely. For information requests, reporting and joint pay assessment, the definition of pay excludes dismissal payments, lump-sum retirement payments and occupational pensions financed by voluntary employee contributions. Pay information not included in a job advertisement must be given in writing before the interview. Information that would identify an individual’s pay goes only to employee representatives, the Labour Inspector or the Commissioner for Administration.
Penalties in the published draft include imprisonment of up to six months, a fine of up to €10,000 or both, with liability extending to directors and officers in some cases. Article 23 of the Directive leaves the type of penalty to Member States, provided the penalties include fines.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: pay information not included in the job advertisement must be given to candidates in writing before the interview. Article 5(1) of the Directive does not prescribe the form.
Proposed: employers would have one month to give a substantiated reply to requests for clarification of reported data. Article 9(10) of the Directive requires a reply within a reasonable time.
Czechia
Current implementation status and timeline
Status: Bill at parliamentary stage.
The government submitted the bill to the Chamber of Deputies on 8 September 2026 as print 300. It combines pay transparency with the rules on platform work. On 1 October 2026 the Organisational Committee recommended it for consideration, with the Social Policy Committee as lead committee. It was proposed for the agenda of the sitting beginning on 13 October 2026. The bill would take effect on 1 January 2027, with some provisions from 1 January 2028 and 1 January 2031. The ministry says first reports would be due in 2028 for employers with 150 or more employees and in 2031 for those with 100 to 149.
What has been transposed into legislation and draft legislation
Text analysed: the bill as summarised by the Ministry of Labour and Social Affairs on 31 August 2026. The pre-employment rule, the reporting dates and the commencement dates were checked against the bill text (print 300).
Nothing has been transposed. Applicants must be told the minimum pay and any other monetary or non-monetary benefits in advance. This can be done in the advertisement, during selection or at contract signing. Employers may not ask about previous pay. These rules also cover agreements to perform work outside an employment relationship (DPP and DPČ).
Workers can request in writing their own pay and the average pay in their group of work by sex. Employers must reply within two months and remind employees of the right at least once a year.
Reporting applies to employers with 100 or more employees. It draws on the Unified Monthly Employer Report (JMHZ), the existing monthly employer filing to the state, with pay gaps by category of work added by employers. The ministry, as monitoring body, would publish only anonymised aggregate data by employer size, sector and region.
Where the average hourly gap in a group of work is at least 5%, cannot be justified and is not corrected within six months, the employer must analyse the causes, review its pay system, take corrective measures and discuss the assessment with employee representatives.
Gaps compared with the Directive
The pre-employment disclosure covers minimum pay. Article 5(1)(a) of the Directive refers to the initial pay or its range.
First reports would be due in 2028. Article 9(2) and (3) of the Directive set 7 June 2027.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: every employer must have a documented remuneration system, set out in an internal regulation or a collective agreement, that defines groups of work of equal value, assigns employees to them and sets pay rules. Article 4(1) of the Directive requires pay structures that ensure equal pay without prescribing a documented system in this form.
Proposed: employers must send the report on pay gaps by group of work to the ministry and make it available to employees by 30 April (section 37i(2) of the Labour Inspection Act and section 306c(1) of the Labour Code, as amended by the bill). The Directive’s date is 7 June.
Denmark
Current implementation status and timeline
Status: Bill at parliamentary stage.
Bill L 68 amending the Equal Pay Act was tabled in the Folketing on 8 October 2026. The Ministry of Employment says it carries out the implementation agreement reached by the labour market parties. The proposed entry into force is 1 March 2027, two months later than in the consultation draft of 26 February 2026. The general election of 24 March 2026 interrupted the process.
What has been transposed into legislation and draft legislation
Text analysed: the consultation draft of 26 February 2026. Bill L 68 of 8 October 2026 was checked only for its start date.
Nothing has been transposed. The detail below comes from the consultation draft. Bill L 68 may differ on points other than the start date.
Applicants receive the starting pay or its range and the pay provisions of any applicable collective agreement. Employers may not ask about pay history.
Workers can request their own pay level and average pay levels by sex for their category. Employers must reply in writing within two months.
Employers with 250 or more employees would file their first report, for 2027, by 1 September 2028 and annually after that. Employers with 150 to 249 would also report first by 1 September 2028 and then every three years. Employers with 100 to 149 would report from 1 September 2031.
A new national body, Arbejdsmarkedets Institut for Ligeløn (AIFL), would receive pay reports and joint pay assessments and help employees obtain pay information. Statistics Denmark and employer organisations could prepare reports for employers. Parts of the Act could be replaced by equivalent rights and duties in collective agreements.
The draft does not use the Article 6(2) option to exempt employers with fewer than 50 workers from providing progression criteria. The employers’ association KA raised this in consultation.
Gaps compared with the Directive
First reports would be due by 1 September 2028. Article 9(2) and (3) of the Directive set 7 June 2027.
Gold plating
Permitted options used (the Directive expressly allows these)
Proposed: reporting would extend to employers with 50 to 99 employees where a job group in the Danish occupational classification (DISCO) has at least eight employees of each sex (Article 9(5)).
Estonia
Current implementation status and timeline
Status: Partial transposing law adopted.
Amendments to the Employment Contracts Act were adopted on 17 June 2026 and took effect on 13 July 2026. On 16 April 2026 the government decided to seek a postponement and amendment of the Directive. It has not published a draft for the remaining provisions.
Why: Economy Minister Erkki Keldo said earlier in 2026 that Estonia would not introduce the legislation because it created additional bureaucracy for employers. The government then chose to transpose the recruitment provisions and seek change at EU level for the rest.
What has been transposed into legislation and draft legislation
Text analysed: the amending act of 17 June 2026 (official text) for the candidate information rule. The other provisions as summarised by ERR News and DLA Piper.
Employers must give candidates the pay or pay range for the position before the job interview, in a form that can be reproduced in writing, in particular in the job advertisement. They may not ask about previous salary. Rules preventing employees from discussing their pay no longer apply. The Employment Contracts Act now states the equal pay principle expressly. Estonia points employers to the voluntary Pay Mirror (Palgapeegel) tool. It uses state statistics to show an employer’s gender pay gap.
Gaps compared with the Directive
Not yet transposed: the right to pay information, pay structures, reporting, joint pay assessment and the enforcement provisions.
Gold plating
Additional requirements (go further than the Directive requires)
Adopted: candidates must receive the pay or pay range before the job interview in a form that can be reproduced in writing (Employment Contracts Act, section 11). Article 5(1) of the Directive does not prescribe the form.
Finland
Current implementation status and timeline
Status: Bill at parliamentary stage.
Government proposal HE 129/2026 vp was submitted to the Eduskunta on 9 July 2026. The referral debate took place on 15 September 2026 and the proposal went to the Employment and Equality Committee. The proposed acts are intended to enter into force on 1 January 2027.
What has been transposed into legislation and draft legislation
Text analysed: government proposal HE 129/2026 vp, as summarised by the Finnish Government and the Incomes Register.
Nothing has been transposed. Employers that regularly employ at least 100 people would report through the Incomes Register. Statistics Finland would compile six of the seven indicators, points (a) to (f) of Article 9(1), from payroll data already in the register. The Incomes Register published reporting guidance on 30 September 2026. Failure to carry out a required joint pay assessment would lead to a negligence fee.
Gold plating
None identified. The government programme commits to promoting pay transparency in line with the Directive’s minimum rules. Existing duties under the Equality Act, including the pay survey, remain.
France
Current implementation status and timeline
Status: Bill at parliamentary stage.
The bill was presented to the Council of Ministers on 10 September 2026 and deposited in the Senate the same day as bill No. 944, with the accelerated procedure engaged. The Senate’s legislative file listed no examination date when it was last updated on 8 October 2026. Public Sénat reported that adoption before the 2027 presidential election looked unlikely given the parliamentary calendar. The government has committed to giving employers a year after adoption to prepare.
A first draft went to the social partners on 6 March 2026. A revised draft that added provisions for public sector employers followed on 4 June 2026.
What has been transposed into legislation and draft legislation
Text analysed: bill No. 944 as described by the government and Public Sénat on 10 September 2026. The phasing of reporting comes from the June 2026 draft and has not been checked against bill No. 944.
Nothing has been transposed. The bill replaces the professional equality index created in 2018 with seven indicators. The labour minister said six of the seven would be automated from existing information systems. Employers must include a salary range in job offers. Employees can obtain the average pay of their category by sex. The minister said each category must contain at least ten people so that individual pay cannot be deduced.
Obligations differ between employers with 50 to 99 employees and those with 100 or more. The June draft phased in reporting for 100 to 149 employees within three years and for 50 to 99 within six years, with dates to be set by decree. Figures are updated annually by companies with 250 or more employees and every three years by smaller companies.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: salary ranges must appear in job offers. Article 5(1) of the Directive gives a published vacancy notice as one of several ways to provide pay information.
Permitted options used (the Directive expressly allows these)
Proposed: the indicator and reporting obligations start at 50 employees, the threshold of the existing index (Article 9(5)). Employer organisations describe this as gold plating. The minister says it avoids a reduction in protection. Article 27(2) of the Directive provides that transposition cannot be grounds for reducing the existing level of protection.
Germany
Current implementation status and timeline
Status: No government draft published.
An expert commission on low-bureaucracy implementation handed its final report to Minister Karin Prien on 7 November 2025. On 2 June 2026 the ministry confirmed that Germany would miss the deadline. It said entry into force is planned for early 2027 and that reporting and the individual right to information would first be due in June 2028. In July 2026 the government told the Bundestag that preparations for a draft had been made but some questions were still being clarified. Ius Laboris reports unconfirmed indications that the cabinet could approve a draft in October 2026.
Why: the ministry has said it is still working on the nature and scope of a privilege for collectively agreed pay rules. It also cited the economic situation. Entries in the Bundestag lobby register, including one from Mercedes-Benz Group dated 16 March 2026, record support for such a privilege.
What has been transposed into legislation and draft legislation
Text analysed: no draft published. The 2017 Pay Transparency Act is the law in force.
Nothing has been transposed. The Pay Transparency Act of 2017 (Entgelttransparenzgesetz) continues to apply. It gives an individual right to information in establishments with more than 200 employees and requires reports from employers with more than 500 employees that must prepare a management report. It presumes that pay rules in collective agreements are appropriate (section 4(5)). Whether a comparable privilege will be kept in the new law is not yet known.
Gold plating
Cannot be assessed until a draft is published. The ministry has said it intends to limit implementation to what is necessary.
Greece
Current implementation status and timeline
Status: Comprehensive transposing law adopted.
Parliament passed Law 5316/2026 on 2 July 2026. It was published in the Government Gazette and entered into force on 6 July 2026. Articles 8 to 20 and 27 apply from 1 November 2026. They cover pay structures, recruitment, the right to information, reporting, joint pay assessment, remedies and burden of proof. Ministry of Labour circular 26923 of 7 October 2026 explains how the law applies.
What has been transposed into legislation and draft legislation
Text analysed: Law 5316/2026 as summarised by Lewis Silkin and Zepos & Yannopoulos. Ministry of Labour circular 26923 of 7 October 2026.
The Greek Ombudsman is the equality and monitoring body and receives the reports. The Labour Inspectorate enforces.
Every employer must have pay structures from 1 November 2026, regardless of headcount. Employers with fewer than 50 employees are exempt only from providing progression criteria.
Applicants receive the initial pay or its range, in writing or orally, with information on any applicable collective agreement. This must happen before the interview or, where there is no interview, before the contract. The pay history ban covers anyone acting on the employer’s behalf and all communications about access to employment.
Employees can request pay information with a two-month response period. Employers may refuse manifestly disproportionate or abusive requests. The employee can then seek the information through the Ombudsman. Employers must tell all employees of the right every year.
Where disclosure would reveal an identifiable worker’s pay, access is limited to workers’ representatives, the Labour Inspectorate and the Ombudsman. The circular says there is no numerical threshold for this test and each case is assessed on its facts.
First report (transitional rule): employers with 150 or more employees report by 7 June 2027 on 1 November to 31 December 2026 (Article 30(1) of the law, as explained in the circular).
Normal cycle: employers with 250 or more employees report by 7 June each year. Employers with 150 to 249 report every three years. Employers with 100 to 149 first report by 7 June 2031 and then every three years. Management confirms accuracy in writing after consulting workers’ representatives.
A collective agreement that sets pay on gender-neutral criteria creates a presumption of no unjustified pay discrimination.
For a joint pay assessment where there is no trade union, the three employees with the longest service represent the workforce unless they choose another method.
Fines range from €300 to €50,000 per violation. Repeated serious violations can lead to temporary closure of all or part of a business, as a specific penalty for repeated infringements under Article 23(4).
Gaps compared with the Directive
The first report covers 1 November to 31 December 2026. Article 9(2) and (3) of the Directive require the report due by 7 June 2027 to cover the previous calendar year (2026).
Lewis Silkin notes that the law omits the Directive’s statement that relevant soft skills must not be undervalued (Article 4(4)).
Lewis Silkin notes that Article 24 on public procurement is not expressly transposed because existing Greek law already excludes employers that breach labour law from tenders.
Gold plating
Additional requirements (go further than the Directive requires)
Adopted: pay structures must be documented in writing, include a review procedure and set out the pay elements for each category of worker. Articles 4(1) and 6(1) of the Directive do not prescribe this form.
Adopted: unjustified differences must be corrected within one year of the joint pay assessment being notified. Article 10(4) of the Directive refers to a reasonable period.
Adopted: pay negotiation must be documented and transparent. Article 5(1) of the Directive requires information that ensures an informed and transparent negotiation without requiring the negotiation to be documented.
Adopted: employees and representatives who receive other workers’ pay data are bound by a statutory duty of confidentiality, with a right for the employer to claim compensation for breach. Article 7(6) of the Directive allows employers to restrict the use of the information.
Adopted: in a Labour Inspectorate procedure on a pay discrimination complaint, the employer must produce pay-setting information within 15 days. Failure to provide it is treated as failure to justify the difference. The Directive sets no time limit for this.
Adopted: employers must answer requests for clarification of reports within two months. Article 9(10) of the Directive refers to a reasonable time.
Hungary
Current implementation status and timeline
Status: No government draft published.
In June 2026 the Ministry of Social and Family Affairs said codification work had been under way for months. It expected a draft to go to public consultation during the summer. No draft had been published by early October 2026. Parliamentary elections took place on 12 April 2026 and the new National Assembly first sat on 9 May 2026. Ius Laboris reports that the government’s autumn 2026 legislative programme plans adoption of a transposing law in October 2026.
Why: the ministry describes transposition as an extremely complex legislative process. The election and the formation of a new parliament fell in the final months before the deadline. Bird & Bird notes that Hungary has no existing gender pay gap legislation to build on.
What has been transposed into legislation and draft legislation
Text analysed: none published.
Nothing has been transposed and no draft has been published.
Gold plating
Cannot be assessed until a draft is published. Before the election, Bird & Bird reported that Hungary intended to meet the minimum requirements.
Ireland
Current implementation status and timeline
Status: Government draft or proposal published.
The published proposal is the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024, published on 15 January 2025. It covers two pre-employment measures from the Directive. These measures are expected to move into a Pay Transparency Bill. Neither a Pay Transparency Bill nor a General Scheme for one has been published.
In a written answer on 26 May 2026 Minister Norma Foley confirmed that Ireland would not be fully transposed by 7 June. She said implementation would proceed on a phased basis and that employers would not be penalised for not having all elements of the Directive in place by June 2026. Ius Laboris reports that the government’s autumn legislative programme, published on 16 September 2026, did not give the Pay Transparency Bill priority drafting status.
Why: the Minister cited the late completion of Commission workshops and the late publication of the EIGE and Commission job evaluation guidance. The employer group Ibec has asked for a delay to June 2027. The Irish Congress of Trade Unions has estimated that each year of delay costs women workers over €570 million in lost wages.
What has been transposed into legislation and draft legislation
Text analysed: the General Scheme published on 15 January 2025, as summarised by Lewis Silkin.
Nothing has been transposed. The General Scheme would require salary levels or ranges in job advertisements and ban questions about pay history. It does not cover the Directive’s other rights and duties. Gender pay gap reporting under the Gender Pay Gap Information Act 2021 continues.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: the General Scheme would require salary levels or ranges in job advertisements. Article 5(1) of the Directive gives a published vacancy notice as one of several ways to provide pay information. The rest of the Irish transposition cannot be assessed until a Pay Transparency Bill is published.
Italy
Current implementation status and timeline
Status: Comprehensive transposing law adopted.
Legislative Decree No. 96 of 7 May 2026 was published in the Official Gazette (No. 125) on 1 June 2026 and entered into force on 7 June 2026. The decree provides for implementing measures. Article 9(4) requires ministerial decrees on data collection, adopted after consulting the Data Protection Authority, within 90 days of entry into force. Article 14(5) requires decrees on the monitoring body within 180 days. The Minister of Labour may issue guidance on equal work and work of equal value by 31 December 2026 (Article 4(6)).
What has been transposed into legislation and draft legislation
Text analysed: Legislative Decree No. 96/2026 (official text).
Pay information and the applicable CCNL must be given in the notices by which job opportunities are made known. Employers may not ask about previous pay, directly or through recruiters (Article 5).
Two definitions need to be kept apart. Pay (retribuzione) is defined as broadly as in the Directive: basic pay and all other amounts and benefits in kind, including complementary or variable components (Article 3(1)(a)). Pay level (livello retributivo) is gross annual and hourly pay counting only fixed and continuous elements. It excludes individual non-structural payments made on a personal, discretionary or temporary basis that are not generalised within the category (Article 3(1)(b)). Pay level is the measure used for information requests and for the gender pay gap (Article 3(1)(c)).
Same work means identical tasks or tasks within the same illustrative job profile at the same pay level and legal category of the CCNL applied. Work of equal value means different work with comparable tasks under the CCNL classification levels (Article 4(2)).
Work of equal value is assessed on skills, responsibilities and working conditions and any other relevant factor (Article 4(3)). CCNL classification systems are the reference for comparisons. An employer’s own classification and evaluation system is permitted as a supplement to the CCNL if it is objective and gender-neutral (Article 4(4)).
Applying a CCNL signed by the comparatively most representative unions creates a presumption of conformity, without prejudice to proof of discriminatory individual pay treatment (Article 4(1)).
The information notice given on hiring is the ordinary way to make pay criteria accessible. For employers applying a representative CCNL, the duty is met by reference to the CCNL and any company agreements. Employers with fewer than 50 employees need not provide progression criteria (Article 6).
Workers may request in writing the average pay levels by sex for categories doing the same work or work of equal value, no more than once a year, with a reply within two months. Employers may meet the duty by publishing the averages on their intranet or in a reserved area of their website. Employers must tell workers of the right annually. Pay confidentiality clauses are prohibited (Article 7).
Where information would reveal an identifiable worker’s pay, access is reserved to workers’ representatives, the Labour Inspectorate and the equality advisers (Article 11(2)). For employers with up to 49 employees, information may be provided by the method to be set by ministerial decree (Article 7(8)).
Reporting applies to employers with at least 100 employees. Data is collected by 7 June 2027 for employers with 150 or more employees and by 7 June 2031 for those with 100 to 149. Groups with a unified pay policy may aggregate data at national level (Article 9).
A joint pay assessment is required where a 5% difference is neither justified nor corrected within six months of the data being communicated. Corrective measures follow within a reasonable time (Article 10).
Gaps compared with the Directive
Each worker may make one request a year (Article 7(1)). Article 7 of the Directive sets no limit.
Effort is not listed among the criteria for work of equal value (Article 4(3)). Article 4(4) of the Directive lists it.
Pay level counts only fixed and continuous elements. The Directive defines pay level as gross annual pay and the corresponding gross hourly pay, based on its broad definition of pay (Article 3(1)(a) and (b)). The narrower Italian definition affects the measures that use pay level. It does not change the Italian definition of pay.
Gold plating
Additional requirements (go further than the Directive requires)
Adopted: pay information must appear in job notices. Article 5(1) of the Directive gives a published vacancy notice as one of several ways to provide it.
Adopted: requests for clarification of reported data must be answered with a reasoned reply within 60 days (Article 9(7)). Article 9(10) of the Directive requires a reply within a reasonable time.
Latvia
Current implementation status and timeline
Status: Government draft or proposal published.
The Ministry of Welfare published a draft Pay Transparency Law on 26 March 2026. Consultation closed on 9 April 2026. A second version was in inter-ministerial coordination in July 2026. The Cabinet has not approved it.
Why: progress stalled at Cabinet level from April 2026. The Latvian Large Cities Association objected to a standalone law and asked for the rules to go into the Labour Law. The Employers’ Confederation of Latvia (LDDK) raised concerns about legal certainty and administrative burden. A new government took office in May 2026 and parliamentary elections were held on 3 October 2026.
What has been transposed into legislation and draft legislation
Text analysed: the draft of 26 March 2026, as summarised by ELA, LDDK and Lewis Silkin. The second version of July 2026 has not been analysed.
Nothing has been transposed. The draft is a standalone law covering recruitment transparency, access to pay criteria, the right to information, reporting and joint pay assessment. The Cabinet would set reporting procedures by 1 May 2027. The Central Statistical Bureau would publish the data in a form that allows comparison between employers, sectors and regions, as Article 29(3)(c) of the Directive requires.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: Lewis Silkin reports a proposed reporting date of 1 June. The Directive’s date is 7 June.
Existing rule: Latvia’s Labour Law already requires job advertisements to state the gross monthly or annual salary range or the hourly rate. Article 5(1) of the Directive gives a published vacancy notice as one of several ways to provide pay information.
Lithuania
Current implementation status and timeline
Status: Comprehensive transposing law adopted.
The Seimas adopted Law No. XV-969 amending the Labour Code on 21 May 2026. It took effect on 7 June 2026, with the main obligations applying from 1 January 2027. Employers must have compliant pay systems by 31 December 2026. The right to information applies from 1 January 2027. The implementing procedure for collecting and publishing the data was published on 17 July 2026.
What has been transposed into legislation and draft legislation
Text analysed: Law No. XV-969 and the implementing procedure, as summarised by the Ministry of Social Security and Labour, Sodra, Sorainen, Trusaic and KIZNE. The official register entry confirms the adoption, publication and commencement dates. The full text could not be retrieved for this review.
The pay history ban and the ban on pay secrecy apply now.
Employers with fewer than 50 employees are exempt from setting pay increase criteria.
Where a reply would reveal an identifiable colleague’s pay, the information goes to employee representatives, the State Labour Inspectorate or the Equal Opportunities Ombudsperson.
Reporting is split between the employer and Sodra, the social insurance board.
What the employer submits: each employee’s job group, working time norm and working time regime, filed once and updated on change. Each month, accrued pay, additional pay such as bonuses and paid working time. Trusaic reports that the first monthly submission is due by 28 February 2027 for January 2027.
What Sodra calculates and sends: average hourly pay for each employee and by sex for each job group, sent each month to the employer, the State Labour Inspectorate and the Equal Opportunities Ombudsperson. Trusaic reports that monthly figures start on 15 March 2027 and annual indicators on 15 March 2028. Breakdowns by job group are visible only in the employer’s account.
What is published: monthly average hourly pay for women and men for each employer with at least eight employees, including more than three women and more than three men. Indicators (a) to (f) of Article 9(1) for employers with 150 or more insured persons by 1 April 2028 and for those with 100 to 149 by 1 April 2031.
What the employer must do with the results: Sorainen reports that employers must pass pay gap information by job group to employees and their representatives within one month of receiving it, except where a job group has fewer than three employees of the relevant sex. Sorainen also reports that unjustified gaps must be rectified within six months of receiving Sodra’s data, with a joint pay assessment if they are not.
Employers with fewer than 100 employees may take part in the detailed reporting voluntarily.
Gaps compared with the Directive
Monthly data collection starts with January 2027. Sodra’s first annual indicators are due from 15 March 2028. Indicators (a) to (f) for employers with 150 or more are to be published by 1 April 2028. Article 9(2) and (3) of the Directive require the first report, on 2026, by 7 June 2027. None of the sources reviewed describes a report on 2026.
Gold plating
Additional requirements (go further than the Directive requires)
Adopted: every employer must have a written pay system available to all employees. Previously this applied only to employers with 20 or more employees. Article 6(1) of the Directive requires the criteria to be easily accessible without prescribing a written pay system.
Adopted: Sorainen reads the amended Labour Code as requiring a reply to a request for pay information within one month. Where the request comes through the authorities, the period is ten working days. Article 7(4) of the Directive allows up to two months.
Existing rule: from 27 July 2019 Lithuanian job advertisements have had to state the base salary as an amount or a range, including the highest salary available for the position. Article 5(1) of the Directive gives a published vacancy notice as one of several ways to provide pay information.
Permitted options used (the Directive expressly allows these)
Adopted: every employer files monthly pay data with Sodra, whatever its size. Sodra publishes average hourly pay by sex for employers with at least eight employees, including more than three women and more than three men. Article 9(5) allows Member States to require information on pay from employers with fewer than 100 workers. Article 9(8) allows indicators to be compiled from administrative data.
Luxembourg
Current implementation status and timeline
Status: No government draft published.
In a parliamentary answer dated 16 June 2026, Labour Minister Marc Spautz said the bill could not yet be deposited because several ministries and administrations had to be consulted. The Ministry of Labour’s preliminary draft would be adapted after those discussions and then presented to the social partners. He said the government had no intention of reducing the scope of the Directive.
Why: inter-ministerial consultation. The Minister reported a meeting with the Ministry of the Economy, the Ministry of Gender Equality and Diversity and the social security bodies on administrative simplification for employers.
What has been transposed into legislation and draft legislation
Text analysed: no draft published. The content below is from the Minister’s parliamentary answer of 16 June 2026.
Nothing has been transposed. The Minister said the preliminary draft will include the right to information, the candidate’s right to the initial pay or range and a ban on asking candidates about current or previous pay.
Gold plating
Cannot be assessed until a draft is published.
Malta
Current implementation status and timeline
Status: Comprehensive transposing law adopted.
The Equal Pay (Transparency and Reporting) Regulations, 2026 (Legal Notice 173 of 2026) were published in the Government Gazette on 5 June 2026. Legal Notice 112 of 2025 had already introduced pre-employment pay information and a right to request pay information from 27 August 2025.
What has been transposed into legislation and draft legislation
Text analysed: Legal Notice 173 of 2026 (official text).
The regulations apply to public and private employers. The Department for Industrial and Employment Relations is the Monitoring Body. The National Commission for the Promotion of Equality is the Equality Body.
Pay structures must allow comparison on skills, effort, responsibility and working conditions, taking account of soft skills, using criteria agreed with employees’ representatives where they exist (regulation 3(3)).
Employers must adopt written pay criteria accessible to workers at all times. Employers with fewer than 50 workers are exempt from the progression element. Those with 25 to 49 must still document progression criteria internally (regulation 5).
Applicants have a right to the initial pay or range and relevant collective agreement provisions before the recruitment process concludes. Pay history questions are banned (regulation 4).
Requests for pay information (regulation 6): workers can request their pay level and the average levels by sex for their category. The employer must reply in writing within eight days. If it does not, an employees’ representative may request the information within twelve days after that period. The worker may then use the Equality Body. Failure to provide complete and accurate information within 45 days of the first request is an offence. Requests made in 2026 cover 2026 pay only.
Workers may not be prevented from disclosing their pay to the authorities, employees’ representatives or their chosen union to enforce the regulations (regulation 6(7)). Where disclosure would reveal an identifiable worker’s pay, only workers’ representatives, the Equality Body and the Monitoring Body have access (regulation 19(3)).
Pay gap reporting (regulation 9): this is a separate process from requests. Reporting applies from 100 workers. Employers with 250 or more report by 7 June 2027 for calendar year 2026 and annually after that. Employers with 150 to 249 report by 7 June 2027 for 2026 and next for 2029. Employers with 100 to 149 report by 7 June 2031 for 2030. Management confirms accuracy after consulting representatives.
Regulation 9(5) also requires reports to be submitted within 14 working days from the end of a relevant yearly period. The regulations do not define that period. How this fits with the 7 June dates is unclear on the face of the text.
A joint pay assessment follows where a 5% difference is neither justified nor remedied within six months of reporting. It must reach the Monitoring Body within ten working days of completion. Remedies follow within a time determined with the employees’ representative, with conciliation and then the Industrial Tribunal if they disagree (regulation 10).
Collective agreements in force when the regulations took effect are deemed valid and compliant until they expire. No recourse lies for terms agreed in them during that period. Claims for breach of the agreement itself remain possible (regulation 23(6)).
Any contravention is a criminal offence with a fine of €2,500 to €5,000, rising to €5,000 to €7,000 where it is connected with a breach of equal pay. Repeated infringement attracts a higher fine within those limits (regulation 20).
Gold plating
Additional requirements (go further than the Directive requires)
Adopted: every employer must adopt and maintain written pay criteria, accessible to workers at all times (regulation 5(1)). Article 6(1) of the Directive requires the criteria to be easily accessible without prescribing a written policy.
Adopted: the employer must reply to a request for pay information within eight days (regulation 6(2)). Article 7(4) of the Directive allows up to two months.
Adopted: information and data relating to requests must be kept for at least five years (regulation 6(8)). The Directive sets no retention period.
Adopted: where a claim reaches the Industrial Tribunal and no categorisation of workers exists, the Tribunal must appoint an expert to carry it out (regulation 14(7)). The Directive has no equivalent provision.
Netherlands
Current implementation status and timeline
Status: Bill at parliamentary stage.
Bill 36949 is before the House of Representatives. The government announced in September 2025 that it could not meet the deadline and set a target of 1 January 2027. The bill went to the Council of State on 19 January 2026. Its advice was dated 2 April 2026. The plenary debate is scheduled for the second week of January 2027. Ius Laboris considers the 1 January 2027 date uncertain.
What has been transposed into legislation and draft legislation
Text analysed: Bill 36949 and the Council of State’s advice, as summarised by Stibbe and Ius Laboris.
Nothing has been transposed. The government describes the bill as a 1:1 implementation. The Council of State noted that reports can be largely prepared by a government body. It raised the tension with privacy law and the lack of clarity about the monitoring body.
Gaps compared with the Directive
First reports for employers with 150 or more employees would cover 2027 and be due by 7 June 2028. Article 9(2) and (3) of the Directive set 7 June 2027. The Council of State advised that the Dutch timing conflicts with the Directive.
Gold plating
None identified. The government’s stated approach is 1:1 implementation.
Poland
Current implementation status and timeline
Status: Partial transposing law adopted.
An Act of 4 June 2025 amending the Labour Code took effect on 24 December 2025. It covers pre-employment pay information, the pay history ban and gender-neutral job titles and advertisements. The remaining provisions are in draft act UC127. A revised draft dated 29 April 2026 was published on 4 May 2026 and awaits review by Council of Ministers committees before referral to the Sejm. It would take effect six months after publication.
What has been transposed into legislation and draft legislation
Text analysed: the Act of 4 June 2025 as summarised by Grant Thornton. Draft UC127 of 29 April 2026 as summarised by L&E Global and Bird & Bird.
In force: pay or pay range information for candidates, the pay history ban and gender-neutral job titles and advertisements.
Draft: a pay structure means ordered pay ranges for positions or types of work resulting from job evaluation. Employers must apply uniform evaluation criteria agreed with trade unions. Without agreement, the employer may set criteria unilaterally using only the Directive’s mandatory criteria.
Draft: pay levels for information requests are calculated over the 12 months before the request.
Draft: employers with 100 or more employees report. User undertakings report for temporary agency workers. The draft gives a legal basis to exclude contractors with an unexplained gap above 5% from public tenders, as Article 24 of the Directive allows.
Gold plating
Additional requirements (go further than the Directive requires)
Adopted: candidates must receive the pay information in paper or electronic form, in the job advertisement or, failing that, before the interview or before the employment relationship begins. Article 5(1) of the Directive does not prescribe the form.
Proposed: employers would have 30 days to answer information requests and requests to supplement them. Article 7(4) of the Directive allows up to two months.
Proposed: after the first cycle, reports would be due by 31 March. The Directive’s date is 7 June.
Proposed: the pay structure must include pay ranges for positions. Article 4(1) of the Directive requires pay structures without prescribing pay ranges.
Portugal
Current implementation status and timeline
Status: Government draft or proposal published.
On 5 August 2026 the Ministry of Labour, Solidarity and Social Security published a draft bill for partial transposition (Separata do BTE No. 26/2026). Consultation ran for 20 days, shortened on grounds of urgency. The draft amends Law No. 60/2018 and related legislation. It would take effect on the first day of the month after publication.
What has been transposed into legislation and draft legislation
Text analysed: the draft bill in BTE Separata No. 26/2026 (official text).
Nothing has been transposed. Under the draft, candidates receive the initial pay or range and applicable collective agreement provisions before the contract is concluded. Pay history questions are banned.
Pay criteria must be posted or published on the intranet. Employers with fewer than 50 employees are exempt from the progression element.
Workers can request pay information with a two-month response period, personally, through representatives or through the Commission for Equality in Labour and Employment (CITE). Employers must tell workers of the right annually.
Employers with 50 or more employees supply data to a designated entity that determines the indicators. They may correct submitted data within 15 days. The entity publishes pay gap information at national, regional, sector and employer level by the end of the first half of each year.
The labour inspectorate asks the employer to justify gaps or present corrective measures within 90 days. Where an unjustified gap of at least 5% remains, it notifies the employer to present a joint pay assessment within 45 days. The measures must be implemented within 90 days with a report to the inspectorate.
Gaps compared with the Directive
Pay is defined as what is due under the employment contract. Article 3(1)(a) of the Directive covers any consideration received directly or indirectly.
There is no right to request clarification of inaccurate individual information. Article 7(2) of the Directive provides one.
The joint pay assessment depends on notification by the inspectorate. Under Article 10(1) of the Directive it arises when the conditions are met.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: the pay policy must be agreed with workers’ representatives where they exist. Article 4(4) of the Directive requires agreement on the evaluation criteria.
Proposed: fixed deadlines replace the Directive’s reasonable period: 30 days to answer clarification requests on reported data (Article 9(10)), 90 days to justify or present corrective measures and 90 days to implement the measures from a joint pay assessment (Article 10(4)).
Proposed: on an individual complaint to CITE, the employer has 30 days to respond. Where CITE finds indications of discrimination, the employer has 30 days to justify the difference or propose corrective measures to be applied within 180 days. The Directive does not set these deadlines.
Permitted options used (the Directive expressly allows these)
Proposed: reporting starts at 50 employees, with employers of 50 to 149 first reporting by 7 June 2031 (Article 9(5)).
Romania
Current implementation status and timeline
Status: Bill at parliamentary stage.
The Ministry of Labour published a draft on 30 March 2026. On 17 June 2026 a group of MPs submitted a legislative proposal to the Senate under the urgent procedure, registered as L445/2026. On 21 September 2026 the Senate extended the period before tacit adoption from 45 to 60 days. Forbes Romania reports that the period ends on 17 October 2026. The Chamber of Deputies then decides. The Legislative Council gave a negative, consultative opinion citing vague definitions. The Economic and Social Council and the National Council for Combating Discrimination gave favourable opinions.
What has been transposed into legislation and draft legislation
Text analysed: legislative proposal L445/2026, as summarised by Littler and Popovici Nitu Stoica.
Nothing has been transposed. The bill follows the Directive’s reporting thresholds and frequency. Reports go to the National Agency for Equal Opportunities between Women and Men (ANES) with no public disclosure. Methodology will be set by ministerial order.
Fines range from three to five gross national minimum wages. Repeated breaches attract five to ten.
Gaps compared with the Directive
Worker is not defined.
Remuneration is defined as gross remuneration including base salary, allowances and bonuses. Littler notes this is narrower than the Directive’s definition of pay (Article 3(1)(a)). The Directive’s definition also covers benefits in kind.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: candidates must be told in writing before the interview of the initial pay or range, including variable components and benefits. Oral disclosure is not sufficient. Article 5(1) of the Directive does not prescribe the form.
Proposed: employers must answer information requests within 30 working days. Article 7(4) of the Directive allows up to two months.
Proposed: employers must set up a company-level structure responsible for eliminating gender pay differences. The Directive has no equivalent requirement.
Slovakia
Current implementation status and timeline
Status: Comprehensive transposing law adopted.
Act No. 76/2026 Coll. on equal pay for men and women for equal work or work of equal value was adopted on 15 April 2026 and took effect on 7 June 2026. Employers established before 7 June 2026 had until 31 July 2026 to put compliant pay structures in place (section 18(1)). The Ministry of Labour issued non-binding guidelines on 30 June 2026.
What has been transposed into legislation and draft legislation
Text analysed: Act No. 76/2026 Coll. (official text).
Pay covers the basic wage and any other monetary or in-kind benefits (section 2(1)(a)).
Criteria are complexity, responsibility, strenuousness, working conditions and other relevant factors, taking account of soft skills, in particular social and communication skills. They are agreed with employee representatives where they exist (section 3).
Applicants receive the starting pay or range and relevant collective agreement provisions before the interview or before the contract is concluded. The duty is met if the published job offer contains the information. Pay history questions are banned (section 4).
Employers with fewer than 50 employees need not provide progression criteria (section 5(3)).
Requests for pay information (section 6): employees can request their own pay level and the average pay by sex for their category. Employers reply within two months. The average is first provided for the year 2027 (section 18(2)). Employers may require averages to be kept confidential except when used to enforce equal pay. Contract terms preventing employees from disclosing their own pay are invalid.
The average is not provided to the employee where it would reveal a specific colleague’s pay (section 6(1)(b)). Access to such information is then limited to employee representatives, the labour inspectorate and the Slovak National Centre for Human Rights (section 10(3)).
First report (transitional rule): employers with 150 or more employees report to the Ministry of Labour by 7 June 2027 on 1 August to 31 December 2026 (section 18(3)).
Normal cycle: employers with 250 or more employees report by 15 April each year on the previous calendar year. Employers with 100 to 249 report every three years by 15 April. Employers with 100 to 149 first report by 7 June 2031 for 2030 (section 18(4)). Headcount is the average registered number of employees in the previous calendar year (section 2(2)).
A joint pay assessment applies where a gap of 5% or more is neither justified nor remedied within six months of submitting the report. It must be carried out within two months after that period and given to the ministry. Where there are no representatives, employees may designate one. Otherwise the employer carries it out alone (section 9).
The ministry fines employers €4,000 to €8,000 for failing to report after a further period of at least 15 days. The ministry has reminded employers that the labour inspectorate can impose fines of up to €100,000.
Gaps compared with the Directive
The first report covers 1 August to 31 December 2026. Article 9(2) and (3) of the Directive require the report due by 7 June 2027 to cover the previous calendar year (2026).
Lewis Silkin notes that there is no specific penalty for repeated infringements. Article 23(4) of the Directive requires one.
Gold plating
Additional requirements (go further than the Directive requires)
Adopted: employees of the same sex can claim equal pay for the same work or work of equal value (Labour Code section 119a(2)). The Directive concerns pay between men and women.
Adopted: clarification requests must be answered within 30 days, both for individual pay information (section 6(3)) and for reported data (section 8(8)). Article 7(2) of the Directive sets no deadline. Article 9(10) refers to a reasonable time.
Adopted: a joint pay assessment must be completed within two months (section 9(2)). The Directive sets no deadline for completing it.
Adopted: from 2028 reports are due by 15 April. The Directive’s date is 7 June.
Slovenia
Current implementation status and timeline
Status: No government draft published.
The ministry sent a draft law to the Economic and Social Council in February 2026. The Council set up an expert committee. In June 2026 the ministry said the draft was awaiting discussion there. Slovenian press reported that substantive coordination had not started.
Why: transposition runs through the tripartite Economic and Social Council. The ministry pointed to the complexity of job evaluation against the Directive’s criteria.
What has been transposed into legislation and draft legislation
Text analysed: none published. The content below is as reported in the Slovenian press.
Nothing has been transposed. Reported content includes pay or a pay range for advertised posts, access to the pay structure for employers with more than 50 employees, the right to information and pay gap reporting.
Gold plating
Cannot be assessed until the draft is published. Svet24 reports that the draft would require the basic pay or its range in published vacancy notices. PwC Slovenia reports that the ministry does not expect obligations beyond the Directive.
Spain
Current implementation status and timeline
Status: Government draft or proposal published.
The government published a draft Royal Decree amending Royal Decree 902/2020 on equal pay on 3 August 2026. Consultation ran until 24 August 2026. A Royal Decree is adopted by the government without a parliamentary vote and would take effect the day after publication in the Official State Gazette. The regulatory impact assessment indicates that legislative amendments may follow on burden of proof and sanctions.
What has been transposed into legislation and draft legislation
Text analysed: the draft Royal Decree of 3 August 2026, as summarised by Ius Laboris and Trusaic.
Existing law: every company must keep a pay register. Companies with 50 or more employees must have an equality plan that includes a pay audit. They must justify the register where average pay of one sex exceeds the other by 25% or more.
Draft: workers can request individual pay and average pay, annual and hourly, by sex for their category, with a reply within two months. Requests are limited to one a year unless changes justify another.
Draft: employers with 250 or more employees report by 7 June 2027 and annually; 150 to 249 by 7 June 2027 and every three years; 100 to 149 by 7 June 2031 and every three years. A new Commission for Monitoring Pay Transparency receives reports.
Draft: job evaluation must give each job a score or numerical value using analytical systems that meet standards of adequacy, completeness and objectivity.
Gaps compared with the Directive
Ius Laboris notes that the draft has no pre-employment pay information or pay history ban (Article 5), no express ban on pay secrecy clauses (Article 7(5)), no joint pay assessment on the Directive’s model (Article 10) and no automatic shift of the burden of proof for breach of transparency duties (Article 18(2)).
Requests are limited to one a year unless changes justify another. Article 7 of the Directive sets no limit.
Gold plating
Additional requirements (go further than the Directive requires)
Proposed: unjustified differences found in a pay audit must be remedied within six months under an action plan, whatever their size. Ius Laboris describes this as gold plating for employers below 100 employees and for gaps below 5%.
Permitted options used (the Directive expressly allows these)
Proposed: reporting would extend to employers with 50 to 99 employees, first by 7 June 2031 and every three years (Article 9(5)).
Sweden
Current implementation status and timeline
Status: Government draft or proposal published.
On 15 January 2026 the government referred a draft bill to the Council on Legislation (lagrådsremiss) amending the Discrimination Act, with entry into force on 1 July 2026. On 11 March 2026 it said it intended to propose moving entry into force to 1 January 2027 and the first pay reports to the Equality Ombudsman to 20 May 2028.
On 26 March 2026 the government announced that it did not currently intend to present a bill to the Riksdag. It said it would seek a postponement of the deadline and a renegotiation of the Directive to simplify it. In the election of 13 September 2026 the centre-left opposition won 176 of 349 seats. Prime Minister Ulf Kristersson resigned on 17 September.
Why: the outgoing government considered the Directive too administratively burdensome. The Discrimination Act already requires pay surveys and cooperation with employee representatives. The government notes that these correspond in part to the Directive.
What has been transposed into legislation and draft legislation
Text analysed: the lagrådsremiss of 15 January 2026, as summarised by the government and MAQS.
Nothing has been transposed. The draft bill would give jobseekers the starting salary or its range and give employees information on their own pay and average pay by sex for equal or equivalent work. Certain employers would carry out written pay surveys and submit pay reports to the Equality Ombudsman. MAQS reports a two-month response period, annual reporting from 250 employees, three-yearly reporting from 100 to 249, written pay surveys from 25 employees and administrative sanction fees.
Gaps compared with the Directive
The government said on 11 March 2026 that it intended to propose first pay reports by 20 May 2028. Article 9(2) and (3) of the Directive set 7 June 2027.
Gold plating
Not assessed. The draft bill was put on hold before reaching the Riksdag and the incoming government may change it.
Practical example: a proposed operating model for a five-country employer
The example covers the five Member States with comprehensive transposing laws: Greece, Italy, Lithuania, Malta and Slovakia. It assumes an organisation with more than 250 employees in each country, a CCNL in Italy and employee representatives in each country. Headcount thresholds apply to each employer. The employer is usually the legal entity. A group with more than 250 employees in a country can still have smaller employing entities there. The model therefore includes some controls that do not depend on headcount. Local counsel should confirm how the model applies to a specific organisation.
How to read the practical example
Directive benchmark: the Directive provision concerned. It reaches employers through national law. It is therefore shown separately from the national requirements.
National requirements: what each national law requires. Deadlines and triggers are kept separate for each country because they are not interchangeable.
Proposed design: how the organisation could meet the requirements with one process.
Internal standard or internal control: a control the organisation chooses for itself, such as a response time stricter than some national laws require or a retention period the law does not set. Each is labelled as such. It is a design choice and does not change any legal requirement.
1. Job evaluation and pay structure
Directive benchmark
Article 4(4): pay structures must allow the value of work to be assessed on objective, gender-neutral criteria agreed with workers’ representatives where they exist. The criteria include skills, effort, responsibility and working conditions.
National requirements
Slovakia: pay structures using complexity, responsibility, strenuousness and working conditions, taking account of soft skills, with criteria agreed with representatives where they exist. The deadline for existing employers was 31 July 2026.
Lithuania: a written pay system available to all employees by 31 December 2026. Sorainen reports a duty to inform and consult employee representatives before the pay system is approved or amended.
Greece: written pay structures with a review procedure and the pay elements for each category, for every employer from 1 November 2026. Criteria are agreed with workers’ representatives where they exist. The ministry accepts global policies that apply in Greece and meet Greek requirements.
Malta: the four Directive criteria, taking account of soft skills, agreed with representatives where they exist. Written pay criteria must be accessible at all times.
Italy: the CCNL classification is the reference for legal comparisons. An employer’s own evaluation system is permitted as a supplement if objective and gender-neutral.
Proposed design
Use one analytical, points-based job evaluation scheme across the five countries. Define the factors so that each statutory term has a visible home. Skills covers social and communication skills and maps to the Slovak criterion of complexity. Effort maps to the Slovak criterion of strenuousness. Responsibility and working conditions are separate factors.
Evaluate every role and hold the scores and evidence for each role in one record.
Use the scheme as common evidence of the value of work. The legal categories are set country by country. In Italy, the CCNL classification sets the categories for legal comparisons. In Lithuania, the categories are the job groups defined in the written pay system and reported to Sodra. In Greece, Malta and Slovakia, the employer groups workers using the national criteria, with representatives involved as each law requires.
Internal standard: agree the criteria with workers’ representatives wherever they exist, in all five countries, following each country’s law and practice on who the representatives are. Greece, Malta and Slovakia require this expressly. In Italy and Lithuania it follows the Directive benchmark.
Set the factor weights as a separate step and record the reasons for each weight. Article 4(4) refers to agreement on the criteria. Check whether national law or practice gives representatives a role in setting the weights.
Write one Pay Structure and Pay Setting Policy covering criteria, categories, pay ranges, the pay elements in each category, progression rules and an annual review procedure. Add a country annex for each of the five. The Lithuanian annex serves as the written pay system made available to all employees.
Internal standard: publish progression criteria to all employees in all five countries, whatever the headcount of the local employing entity.
Italian annex. The annex should separate three things. First, the comparisons the law requires. Same work and work of equal value are defined by reference to the CCNL levels and legal categories (Article 4(2)). These define the categories for Italian reporting and information requests. Second, the internal points scheme. The decree permits it as a supplement to the CCNL (Article 4(4)). The organisation uses it to set pay above CCNL minimums on objective criteria and as a diagnostic check across levels. Third, an escalation route. Where the internal scores suggest either that roles at different CCNL levels are of equal value or that roles at the same level differ materially, the case goes to HR and legal review and is discussed with the representatives. The CCNL classification is not changed unilaterally on the strength of the internal score.
2. Recruitment
National requirements
Italy: the initial pay or range and the applicable CCNL in the notices by which jobs are advertised.
Lithuania: the base salary as an amount or a range in job advertisements, including the highest salary available for the position.
Greece: the information before the interview, in writing or orally, with documented and transparent negotiation and a pay history ban that covers anyone acting for the employer.
Malta: the information with relevant collective agreement provisions before the recruitment process concludes.
Slovakia: the information before the interview or before the contract, treated as met if it is in the published offer.
All five ban questions about pay history. Italy’s ban extends to recruiters acting for the employer.
Proposed design
Internal standard: put the pay range for the role’s category in every job advertisement in all five countries. State whether it is gross, set the top of the range at the highest salary available for the position and refer to any applicable collective agreement. Italy and Lithuania require this. In Greece, Malta and Slovakia the advertisement gives the information before the interview. That meets their timing rules. Slovakia’s law says expressly that a published job offer meets the duty.
Send each shortlisted candidate a written confirmation of the range and agreement provisions before the first interview and keep a record of the pay discussion. This creates the documented negotiation record Greece requires.
Remove pay history fields from application forms and interview guides. Add the ban to contracts with recruitment agencies and others acting for the organisation.
Review job titles and advertisement templates for gender-neutral wording.
3. Pay confidentiality
Directive benchmark
Article 7(5): Member States must prohibit contractual terms that restrict workers from disclosing their pay. Article 7(6): employers may require workers not to use information about other workers’ pay for any purpose other than exercising their right to equal pay.
National requirements
Own pay: Italy and Slovakia make terms that restrict disclosure void or invalid. Lithuania’s ban on pay secrecy already applies. Malta provides that workers may not be prevented from disclosing their pay to the authorities, employees’ representatives or their chosen union to enforce the regulations.
Use of information about other workers’ pay: Malta allows employers to restrict it to exercising the right to equal pay. Italy restricts it by law. Slovakia allows employers to require averages to be kept confidential except for enforcing equal pay. Greece imposes a statutory duty of confidentiality on employees and representatives who receive other workers’ data.
Proposed design
Remove any term preventing employees from disclosing their own pay from contracts and policies in all five countries.
Add one clause restricting the use of information about other workers’ pay to the exercise of equal pay rights, with a Greek annex referring to the statutory duty.
4. Requests for pay information
This is a separate process from pay gap reporting in section 5. It is triggered by an individual request and has its own deadlines.
National requirements
Malta: written reply within eight days. If there is no reply, a representative may request within twelve days after that, then the Equality Body. Failure to provide complete and accurate information within 45 days of the first request is an offence. The eight-day deadline and the 45-day offence threshold are separate. Any contravention of the regulations is also an offence (regulation 20).
Lithuania: from 1 January 2027. Sorainen reports a one-month deadline.
Greece: up to two months. Manifestly disproportionate or abusive requests may be refused, with recourse to the Ombudsman.
Italy: up to two months, average pay levels by sex for the category, once a year per worker. The duty can be met by intranet publication. Clarifications receive a reasoned reply.
Slovakia: up to two months. Clarifications within 30 days. The average element is first provided for 2027.
Who receives information that would identify an individual’s pay
Greece: workers’ representatives, the Labour Inspectorate and the Ombudsman. No numerical threshold. Each case is assessed on its facts.
Italy: workers’ representatives, the Labour Inspectorate and the equality advisers. For employers with up to 49 employees, the method set by ministerial decree.
Lithuania: employee representatives, the State Labour Inspectorate or the Equal Opportunities Ombudsperson. Category data is not passed on where a category has fewer than three employees of the relevant sex (Sorainen).
Malta: workers’ representatives, the Equality Body and the Monitoring Body.
Slovakia: the average is withheld from the employee. Access is limited to employee representatives, the labour inspectorate and the Slovak National Centre for Human Rights.
Proposed design
Refresh the category averages each month for every category: annual and hourly, basic and variable, by sex. A request then becomes a retrieval task.
Hold the reference period each law uses for the averages. Slovakia provides the average for a calendar year, first for 2027. Malta limits requests made in 2026 to 2026 pay. Lithuania works from Sodra’s monthly and annual figures. Where a law does not fix the period, state in each reply the period the figures cover.
Hold the pay components needed for both measures. Use pay as defined in the Directive for Greece, Lithuania, Malta and Slovakia. Use the Italian pay level for Italian requests. It counts fixed and continuous elements only.
Internal standard: reply within eight days in all five countries. Track the legal deadline for each request separately: eight days and the 45-day offence threshold in Malta, one month in Lithuania (on Sorainen’s reading) and up to two months in Greece, Italy and Slovakia.
Internal standard: answer clarification requests within 30 days in all five countries. This is the legal deadline in Slovakia.
Log every request by employee and date. The log supports Italy’s once-a-year limit and Greece’s abusive request rule.
Internal privacy control: before any average is released, check whether it could reveal the pay of an identifiable individual. As a screening rule, refer any category with fewer than three employees of either sex for review. This screen is the organisation’s own control. The legal test in each country is whether an individual could be identified, with the recipients listed above.
In Lithuania, add a monthly step to pass Sodra’s job group information to employees and representatives within one month of receipt. Sorainen reports that this does not apply where a job group has fewer than three employees of the relevant sex.
Send one annual notice of the right to all employees in each country.
5. Pay gap reporting
National requirements
Greece: first report by 7 June 2027 on 1 November to 31 December 2026 (transitional rule). Then by 7 June each year. Reports go to the Ombudsman. Management confirms accuracy in writing after consulting representatives.
Slovakia: first report by 7 June 2027 on 1 August to 31 December 2026 (transitional rule). Then by 15 April each year on the previous calendar year. Reports go to the Ministry of Labour. Headcount is the average registered number of employees in the previous calendar year.
Malta: by 7 June 2027 on calendar year 2026, then annually. Regulation 9(5) adds a 14-working-day submission requirement whose relationship to 7 June is not defined. Management confirms accuracy after consulting representatives.
Italy: data collected by 7 June 2027. Article 9(4) of the decree provides for ministerial decrees on collection methods. These may draw on data held by INPS and INAIL. Groups with a unified pay policy may aggregate at national level.
Lithuania: the employer submits data to Sodra each month from January 2027 data. Sodra calculates the indicators and sends them to the employer. Sodra publishes the employer-level figures described in the Lithuania section.
Proposed design
Build one monthly employee-level data set: employee identifier, sex, country, legal entity, internal category, CCNL level for Italy, Lithuanian job group, contract type including agency status, contractual and paid hours, basic pay, each complementary or variable component and the value of benefits in kind.
Produce each country’s figures from that data set for its own reference period: 1 November to 31 December 2026 for Greece, 1 August to 31 December 2026 for Slovakia and calendar 2026 for Malta.
Italy’s decree does not state the reference period for the data collected by 7 June 2027. Article 9(2) and (3) of the Directive refer to the previous calendar year. Prepare calendar 2026 figures and confirm the period when the ministerial decrees under Article 9(4) of the decree are adopted.
For Lithuania, keep three things apart in the system: the data the employer submits, the indicators Sodra calculates and sends back and the figures Sodra publishes. The job group field must match the groups in the Lithuanian pay system. Reconcile Sodra’s figures with the organisation’s own calculation each month.
Ask the Maltese Monitoring Body to confirm how regulation 9(5) applies before the first filing.
Internal standard: complete management review and representative consultation six weeks before the earliest deadline. From 2028 that is Slovakia’s 15 April.
6. Gap review, remediation and joint pay assessment
National requirements
Greece: corrective measures within six months of reporting. A joint pay assessment follows if the gap is neither justified nor corrected in that period. Unjustified differences must be corrected within one year of the assessment being notified.
Slovakia: six months from submitting the report to the ministry. The joint pay assessment must be carried out within two months after that period and given to the ministry. Remedial measures follow within a reasonable period.
Malta: six months from submission. The completed assessment goes to the Monitoring Body within ten working days. Remedies follow within the time determined with the employees’ representative.
Italy: six months from communication of the data. The results go to the monitoring body. Measures follow within a reasonable time.
Lithuania: Sorainen reports a six-month period from receipt of Sodra’s data, with a joint pay assessment if gaps are not rectified.
Proposed design
Run the category gap analysis before each report is filed. Explanations and remediation can then start at once.
Keep one calendar with a separate line for each country, keyed to that country’s own trigger date. Treat Slovakia’s two-month completion period and Malta’s ten working days as fixed. Track Greece’s one-year correction period from the date the assessment is notified.
Internal standard: set internal target dates ahead of each legal date.
• Review any category gap of 5% or more. A joint pay assessment is required where the gap is not adequately justified by objective, gender-neutral criteria and remains unremedied six months after the pay report is submitted, subject to each country’s applicable rules.
Internal standard: also review unexplained pay differences between individuals, whatever the category gap shows. Individual employees can bring equal pay claims on their own comparisons.
In Slovakia, also review unexplained pay differences between employees of the same sex in the same category. The Slovak Labour Code gives them a right to equal pay. Run this review as its own processing activity (section 7). The same applies to any similar review in the other countries.
7. Data protection and governance
Directive benchmark
Article 12: the processing must comply with the GDPR. Personal data may not be used for any purpose other than applying the principle of equal pay (Article 12(2)). Member States may restrict access where an individual’s pay would be revealed (Article 12(3)).
National requirements
Malta (regulations 10(7) and 19), Slovakia (section 10) and Italy (Article 11) transpose these points expressly.
The data set in section 5 holds sex, pay components, working hours, job categories, legal entities and agency status for every employee in five countries.
Proposed design
For each processing activity, record which legal entity is the controller and the lawful basis relied on. Statutory reporting and request handling are legal obligations of the employing entity under national law.
Limit personal data processed for requests for pay information, pay gap reporting and joint pay assessments to applying the principle of equal pay (Article 12(2) of the Directive). Design other analysis, such as general reward analysis or a same-sex pay review, as a separate processing activity using data that can lawfully be processed for that purpose. Taking a separate extract from the pay transparency data set does not by itself permit its reuse.
Run three processes separately on the same data. Each has its own outputs, access rights and retention.
Statutory reporting: the output is the figures filed with each authority and the category data given to employees and representatives. Access: the reporting team and the managers who confirm accuracy. Retention (internal control): keep the reporting information needed to answer requests for the previous four years, where available. Article 9(9) of the Directive sets the duty to provide that information on request. The retention period itself is an operational choice.
Individual requests: the output is a written reply to one worker or a referral to the designated recipients where an individual could be identified. Access: the team handling requests. Retention: at least five years in Malta, where this is a legal requirement (regulation 6(8)). Set an internal period for the other four countries.
Gap review and joint pay assessment: the output is the assessment and the remedial plan, sent to the monitoring body where the law requires. Access: the review team and the representatives taking part. Retention (internal control): long enough for the next assessment to evaluate the measures taken. Article 10(2)(g) of the Directive requires that evaluation.
In all three, HR business partners and managers receive category-level outputs only.
Consider whether a data protection impact assessment is needed under Article 35 GDPR. If any part of the central team sits outside the EU, apply the transfer rules in Chapter V of the GDPR.
The same structure can take further countries as their laws are adopted by adding a country annex, a reporting period and a line in the calendar.
Sources
The position at a glance
European Commission: transposition infringement decisions, INF/26/1380 (15 July 2026)
European Commission: transposition infringement decisions, INF/26/1834 (25 September 2026)
What the national texts show
EIGE: EU-wide guidelines on gender-neutral job evaluation and classification
Lithuanian Ministry of Social Security and Labour: Didinamas atlyginimų skaidrumas (21 May 2026)
Public Sénat: que contient le nouveau projet de loi (10 September 2026)
Country by country
Austria
ORF: Österreich bei EU-Lohntransparenzrichtlinie säumig (15 September 2026)
Tiroler Tageszeitung: Kritik an Schumanns Entwurf zu Lohntransparenz
Belgium
Partena Professional: Belgium requests an additional six months
Legalnews (VBO): Omzetting loontransparantierichtlijn uitgesteld, wat nu?
Bulgaria
Croatia
Cyprus
Philenews: Cyprus parliament dissolves ahead of 24 May 2026 election
George Z. Georgiou & Associates: EU transposition update September 2026
Czechia
Chamber of Deputies: print 300, government bill (submitted 8 September 2026)
Ministry of Labour and Social Affairs: government approves the bill (31 August 2026)
Trusaic: Czechia’s government approves bill (15 September 2026)
Ius Laboris: Which countries have transposed (Czech Republic entry)
Denmark
Dansk Erhverv: Nye regler om løngennemsigtighed udskydes til marts 2027 (8 October 2026)
Focus Advokater: Løngennemsigtighedsdirektivet er omsat til lovforslag
Estonia
Finland
France
Public Sénat: que contient le nouveau projet de loi (10 September 2026)
Service-public.fr: le projet de loi pour la transparence salariale (10 September 2026)
Germany
BMBFSFJ: final report of the commission on low-bureaucracy implementation
ZfK: Umsetzung der EU-Richtlinie verzögert sich (2 June 2026)
Pöppel Rechtsanwälte: EU-Entgelttransparenzrichtlinie, Umsetzung in Deutschland (February 2026)
Bundestag hib 587/2026: Umsetzung der EU-Entgelttransparenzrichtlinie (16 July 2026)
Bundestag lobby register: Mercedes-Benz Group entry RV0023004 (16 March 2026)
Ius Laboris: Which countries have transposed (Germany entry)
Greece
Ministry of Labour circular 26923 of 7 October 2026 (Taxheaven)
Ergasiaka: Μισθολογική διαφάνεια, η νέα εγκύκλιος (October 2026)
Lewis Silkin: Greece transposes the Directive (updated 29 September 2026)
Hungary
Ireland
McCann FitzGerald: Ireland confirms it will not meet the deadline
ICTU: Delayed pay transparency to cost women workers over €570 million a year (5 June 2026)
Italy
Latvia
Lithuania
Ministry of Social Security and Labour: Didinamas atlyginimų skaidrumas (21 May 2026)
Trusaic: Lithuania finalises Sodra reporting mechanics (4 August 2026)
KIZNE: Skaidraus darbo užmokesčio pranešimas Sodrai nuo 2027 m. (9 July 2026)
Ius Laboris: What salary information must be in a job advertisement in Lithuania (2019)
Luxembourg
Malta
Netherlands
Poland
Portugal
Romania
Forbes Romania: Legea transparenței salariale intră în linie dreaptă (9 October 2026)
Littler via Mondaq: Romania rushing to implement (14 July 2026)
Legal 500 (Popovici Nitu Stoica): Pay transparency enters the final stretch in Romania (3 July 2026)
Slovakia
National Council of the Slovak Republic: legislative history
Lewis Silkin: Slovakia becomes the first Member State to transpose (updated 29 September 2026)
Slovenia
Spain
Ministry of Labour and Social Economy: public participation in regulatory projects
Trusaic: Spain proposes rules that exceed Directive minimums
Sweden
Regeringen: Lagrådsremiss Genomförande av lönetransparensdirektivet (15 January 2026)
Regeringen: Regeringen vill omförhandla lönetransparensdirektivet (26 March 2026)
