27 EU countries have until 7 June 2026 to implement the EU Pay Transparency directive 2023/970/EC into domestic law:

Pre-employment transparency:

Employers cannot ask candidates about previous or current salary.

Employers must state salary range in job advertisements

Right to pay information:

Employers must share information on how salary is set.

Employees will be entitled to request information about their salary levels and how it is compared with colleagues performing the same work as them (work of equal value), broken down by gender.

Mandatory reporting:

Employers must report on gender pay gaps and act if unjustified disparities exceed 5%.

Ban on pay secrecy:

Employers cannot prohibit employees from discussing or disclosing their pay.

Sanctions:

EU Countries must establish penalties in case of noncompliance.

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EU Pay Transparency

Per country

Austria

Belgium

Currently, Belgium already mandates annual gender pay gap reporting for companies with more than 50 employees, and employers with more than 100 employees must produce a detailed biennial gender report for their works council. These existing obligations form a strong foundation for the new EU requirements.

Since 1 January 2025, employers subject to the jurisdiction of the Fédération Wallonie-Bruxelles (mainly public sector employers) have had to comply with a new decree which is the first transposition of the Directive into domestic law in any EU member state jurisdiction.

The Fédération has introduced provisions which go beyond the minimum requirements in the Directive, including obligations to (1) make the starting salary or salary range for a job opening available as soon as it is announced and represent this in an accessible format for people with disabilities; (2) use job titles that are “non-discriminatory”; and (3) as part of the Directive gender pay reporting obligations, include an assessment of how periods of family-related leaves of absence have affected remuneration.

The decree does not apply to all Belgian employers. However, it is potentially indicative of how the Directive will be transposed in Belgium more widely. Employers should begin reviewing pay structures and prepare for increased transparency obligations ahead of the 2026 deadline.

Bulgaria

Croatia

Cyprus

Czechia

In Prague, three of the Czech Republic’s most influential employer organizations - the Czech Chamber of Commerce, the Confederation of Industry and Transport, and the Confederation of Employer and Business Associations - have jointly urged the government to delay implementation of the EU Pay Transparency Directive by two years.

The Directive, set for enforcement by June 2026, requires companies to disclose salary structures, uphold equal pay for equal work, and allow employees to access gender-based pay data. However, these business groups argue that the current timeline threatens economic stability and competitiveness, particularly for small and medium-sized enterprises. They cite a lack of readiness, increased legal risks, and administrative burdens.

Ironically, the Czech Republic currently has the worst gender pay gap in the EU at 18% highlighting the urgent need for reforms. While the employer groups agree with the directive objective of gender pay equality, they caution that a rushed rollout without support infrastructure could do more harm than good.

They also oppose the right to disconnect, a separate EU initiative that would give employees the legal right to disengage from work on communications outside working hours. Employers argue it could hinder flexibility, especially in sectors like IT and services.

The Czech Labour Ministry has yet to formally respond, but pressure is mounting as the June 2026 deadline approaches.

Denmark

Estonia

Finland

Employer organisations in Finland have voiced strong opposition to a government proposal aimed at improving pay transparency, calling it impractical, legally flawed, and overly burdensome. The draft legislation, published as part of Finland’s implementation of the EU’s 2023 pay transparency directive, seeks to give employees greater access to salary information and introduce new employer obligations. These include disclosing starting salaries or salary ranges in job ads, reporting gender-based pay differences in companies with over 100 employees, and providing average salary data for roles of equal value. The proposal also aims to update the Equality Act with clearer definitions of equal work and criteria for comparing job roles, such as required qualifications, responsibility, and working conditions. While the goal is to ensure equal pay for equal work, several major employer organisations - including the Confederation of Finnish Industries (EK), the Association of Finnish Local and Regional Authorities (KT), and the Federation of Finnish Enterprises - issued a joint statement rejecting the draft. They argue that current laws already ensure wage equality and that introducing uniform legal standards across diverse sectors is unrealistic due to the role of collective agreements. Employers also raised concerns about competition law violations if salary ranges are made public, suggesting this could lead to implicit coordination of wages between companies. They further criticised the administrative burden of sharing salary data with employees, especially for larger organisations. In contrast, trade unions such as SAK and Akava support the proposal, advocating for salary transparency from the beginning of the hiring process. While the proposal is still in the drafting stage and subject to revision, employer groups claim it goes beyond the minimum requirements of the EU directive. No final timeline for the law’s adoption has been set.

Credit: Helsinki Times

France already mandates annual gender equality reporting through the Index de l’égalité professionnelle, which applies to companies with at least 50 employees. This index scores companies based on gender pay gaps, promotion rates, and other indicators, with the results made public and corrective actions required for low scores. However, French law does not yet grant employees individual rights to request pay comparison data, nor does it include obligations for salary disclosure in job postings. These gaps will need to be addressed under the EU Directive.

While France already has a robust gender equality framework, the EU Directive will require enhanced transparency rights for individual workers, clearer rules on recruitment pay information, and greater legal protections. The French government is expected to propose legislation in the coming year to bridge the remaining gaps. Employers especially those approaching the 100-employee threshold, should start reviewing their pay structures, job classification systems, and HR policies to prepare for compliance. With the new EU rules, France has an opportunity to reinforce its leadership on gender pay equality while ensuring employers are equipped to handle these evolving obligations.

France

Germany

Germany has taken proactive steps toward promoting pay transparency and gender equality in the workplace, particularly with the enactment of the Pay Transparency Act (Entgelttransparenzgesetz) in 2017. Now, with the upcoming implementation of EU Directive 2023/970/EC, Germany is set to expand and strengthen these measures by June 7, 2026. Under the existing Pay Transparency Act, employees in companies with more than 200 employees have the right to request information about the criteria and procedures used to determine their pay, as well as the median gross monthly pay of colleagues of the opposite gender performing the same or comparable work. Additionally, companies with over 500 employees are encouraged to conduct internal pay audits and report on gender equality and equal pay practices in their management reports. However, enforcement has been limited, and the impact of the law on closing the gender pay gap has been modest. Germany still records a gender pay gap of approximately 18%, one of the highest in Western Europe.

The EU Directive 2023/970/EC, which must be transposed into German law by mid-2026, will introduce stricter and broader transparency and enforcement mechanisms. Germany’s Federal Ministry for Family Affairs, Senior Citizens, Women and Youth has indicated support for the Directive and is expected to propose legislation in line with the EU requirements. This will likely involve amending the existing Pay Transparency Act to broaden its scope and enhance enforcement mechanisms. For employers, this means a significant increase in compliance obligationsincluding revising pay structures, improving documentation, and preparing for possible claims. For employees, the new framework promises greater insight, equity, and recourse in pay matters. Germany’s challenge now is to ensure a smooth transition that balances business concerns with the pressing need to close the country’s persistent gender pay gap.

Greece

Greece does not yet have a comprehensive pay transparency law. Instead, measures related to wage equality are embedded in broader anti-discrimination and labor laws:

1. Greek Constitution (Article 22) that guarantees the right to equal pay for work of equal value, regardless of gender.

2. Law 3896/2010 on the Implementation of the Principle of Equal Opportunities and Equal Treatment of Men and Women in Matters of Employment and Occupation that aligns with EU Directive 2006/54/EC, focusing on gender equality and explicitly requiring equal pay for equal work or work of equal value. However, it lacks specific mechanisms to ensure transparency.

3. While collective labor agreements regulate wages in certain sectors, they do not usually mandate pay transparency measures such as public reporting or salary range disclosures.

4. Employers are required to submit information to the ERGANI platform, Greece central digital employment registry, including data on hires, terminations, and contracts but not detailed wage transparency data by gender or job classification.

   For Greece, implementing this directive will require substantial legal reforms,

   including: Introducing mandatory pay audits and public reporting for larger employers. Creating guidelines for salary range disclosures in recruitment processes. Ensuring trade unions and employee representatives are involved in enforcing transparency standards.

   The Greek Ministry of Labour and Social Affairs is currently working to align national legislation with the directive’s requirements, likely through a new comprehensive law expected by 2026.

Hungary

Ireland

Ireland’s Gender Pay Gap Information Act requires organizations to report on gender pay differences annually. Initially applied to employers with 250+ employees in 2022, the threshold has since dropped to 150 employees in 2024 and will further decrease to 50 employees in 2025. Reports must include metrics such as mean and median pay gaps, bonus gaps, and the proportion of men and women in pay quartiles. While this law has improved transparency, it does not yet cover pre-hiring transparency or give individual employees the right to request pay data, as mandated under the EU Directive. Ireland’s Department of Children, Equality, Disability, Integration and Youth has prepared a draft legislation to transpose the Directive. The government has published the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024. The bill contains two proposed amendments to the Employment Equality Act 1998. Firstly, the bill proposes that organisations must not publish or display an advertisement which relates to employment that does not include the remuneration rate or its range for the post concerned. This amendment technically goes beyond what is provided for in the Directive because it requires employers to provide the information in the job advertisement. The Directive only states that applicants have the right to receive this information from the prospective employer, although it does suggest that the information could be provided via a job advert and in practice, this is how organisations would have likely complied with this obligation in any event. Secondly, employers must not request from job applicants information about the applicant current or former rates. This transposes the corresponding obligation from Article 5 of the Directive. The Directive requirements will need to be addressed in amendments to the bill or in further legislation. Employers, especially those nearing the 100-employee threshold should start preparing now by reviewing pay structures, documenting pay criteria, and ensuring systems are in place to respond to future employee information requests and audit obligations. Ireland evolving legal landscape offers a powerful opportunity to close its gender pay gap, which currently stands at around 11%, while also posing a compliance challenge that requires careful planning.

Italy

Latvia

Lithuania

Symbolically, on May 20, 2025—International HR Day—the Ministry of Social Security and Labour shared a proposal for the implementation of the EU Pay Transparency Directive. Discussions with representatives of workers and employers are now set to begin. This is a partial proposal, as the requirements for periodic pay gap reporting to government bodies and joint pay assessments will be addressed in a separate procedure administered by the Social Insurance and Labour Inspection institutions.

Before employment - Already Existed: Employers must include the amount and/or range of the basic (rate) remuneration (hourly rate, monthly salary, or fixed part of the basic salary) in job advertisements. New Requirements: The collective agreement applicable to the position must be provided before discussing or signing the employment contract. Employers are prohibited from asking applicants about their pay history in current or previous employment.

Pay Gap reporting - Already Existed: The raw pay gap of average total pay is published monthly by the Social Security institution. New Requirements: Workers or their representatives may request pay gap information by work category once per year. Employers must explain discrepancies and correct unjustified pay gaps within six months. This reporting obligation is separate from the periodic reporting to institutions, which may trigger a joint pay assessment. This will be regulated through a separate procedure yet to be published.

Pay structures (systems) - Already Existed: Employers with 20 or more employees must establish a formal pay system in collaboration with workers representatives. This system must ensure the principle of equal pay for equal work and include base pay ranges, variable pay principles, and pay indexing procedure. Relevant definitions are provided: ‘The same work’ means the performance of a work activity which, based on objective criteria, is the same as, or similar to, another work activity to the extent that both employees can be interchanged without significant cost for the employer. ‘Equal work’ means a job that, based on objective criteria, is not less qualified and not less important to the employer’s pursuit of operational objectives than another comparative job. New Requirements: Criteria if company size is removed and all companies shall have a formal pay system. Pay systems additionally shall include: a) work categories which are created based on gender neutral criteria, that shall include skills (including social emotional), effort, responsibility and working conditions, and, if appropriate, any other factors which are relevant to the specific job or position. b) salary increase procedure. Companies with less than 50 employees are not obligated to provide salary increase criteria.

Fines and compensations - New Requirements: The previous maximum compensation limit of six months for pay-related violations has been removed. Maximum fines for non-compliance with pay system regulations or failure to disclose/report pay information are set at €6,000. Initial fines start at €400.

Support for small employers - Already Existed: There are existing guides approved by Ministry of Social Affairs and Labour with regards to job evaluation and pay systems creation. There are currently no plans to revise or supplement these guides. However, it is acknowledged that these resources are not widely used by companies.

Data protection - New Requirements: Employees or their representatives may request pay gap data annually, for work categories with more than two employees. Where personal data protection is at risk, the principle of equal pay must be ensured through employee representatives or external institutions.

Right to information - New Requirements: In accordance with the directive: Workers shall have the right to request and receive in writing, information on their individual pay level and the average pay levels, broken down by sex, for categories of workers performing the same work as them or work of equal value to theirs. If the information received is inaccurate or incomplete, workers shall have the right to request, personally or through their workers’ representatives, additional and reasonable clarifications and details regarding any of the data provided and receive a substantiated reply. Employers shall inform all workers, on an annual basis, of their right to receive the information referred to in paragraph 1 and of the steps that the worker is to undertake to exercise that right. Workers shall not be prevented from disclosing their pay for the purpose of the enforcement of the principle of equal pay Employers may require workers who have obtained information pursuant to this Article, other than information concerning their own pay or pay level, not to use that information for any purpose other than to exercise their right to equal pay.

Implementation date: June 7, 2026 - Special thanks to Eligijus Kajieta for the above summary.

Luxembourg

Malta

Netherlands

Under Dutch law, equal pay for equal work is already a principle laid out in the Equal Treatment of Men and Women Act. However, there are limited obligations for employers regarding salary transparency, reporting, or employee rights to access comparative pay data. As such, the new EU rules will mark a significant shift. The proposed law introduces several new obligations:

• Gender-neutral pay structures: Employers must implement objective, gender-neutral criteria (e.g. skills, responsibilities) for pay setting and progression.

• Pre-employment transparency: Employers must provide candidates with the initial pay or pay range and may not ask about salary history.

• Pay transparency during employment: Employees may request information about their own pay and average pay by gender for similar roles. Employers with 50+ employees must explain how pay and career progression decisions are made.

• Annual reminders must be issued to employees informing them of their rights.

• Pay gap reporting: Applies to employers with 100+ employees. Reports must show average pay differences between men and women and among job categories. Publication deadlines vary by company size, starting in 2027 (or 2031 for smaller firms). If pay gaps exceed 5% without objective justification, a pay evaluation and action plan is required.

• Enforcement and penalties: The National Labor Authority is empowered to supervise compliance and impose fines (up to €10,300 per violation).

  Affected employees may bring civil claims for equal pay, and the burden of proof shifts to the employer if transparency rules were breached.

• Works councils and trade unions:Must be consulted on pay structures and strategies to close unjustified pay gaps. Employers must also share reporting data and seek the council’s confirmation of its accuracy.

The draft Bill does not provide for transitional periods, meaning most rules (except reporting deadlines) take effect immediately after June 6, 2026. The Dutch government has opted to implement only the minimum required changes, avoiding any additional national obligations. Employers in the Netherlands should begin reviewing their HR and payroll systems, pay policies, and internal communication processes to ensure readiness. Early action is essential, especially given the lack of a grace period once the law comes into force.

Poland

Pay Transparency Laws in Poland: Preparing for EU Directive Implementation Poland is preparing to overhaul its pay transparency framework in light of EU Directive 2023/970/EC, which aims to reinforce the right to equal pay for equal work between women and men. While Poland has existing legal provisions prohibiting pay discrimination, the current system lacks strong transparency and reporting mechanisms. The Directive must be implemented by June 7, 2026. Polish labor law prohibits direct and indirect pay discrimination under the Labour Code. Employees can file complaints or lawsuits if they suspect unequal pay, but access to comparative pay data is limited, and employers are not required to disclose salary information or conduct pay audits. As a result, Poland continues to face a gender pay gap of around 13%, according to Eurostat. The Polish government has not yet published a draft law transposing the Directive, but legislative work is expected in 2025. The implementation will likely involve amendments to the Labour Code and possibly new regulations related to reporting and enforcement. Polish employers should begin assessing their pay structures, documentation processes, and HR systems to prepare for compliance. Although the deadline is in 2026, the scope and complexity of the upcoming rules will require early action especially for companies with larger workforces. The Directive presents a major shift for Poland, offering an opportunity to close the gender pay gap and modernize workplace equality but also bringing significant compliance obligations for businesses.

Portugal

Romania

Slovakia

Slovenia

Spain

Spain has been a front-runner in gender equality legislation in recent years, and the implementation of EU Directive 2023/970/EC will further strengthen its legal framework around equal pay and transparency. The Directive must be transposed into Spanish law by June 7, 2026, and introduces a standardized approach across the EU to combat pay discrimination and promote accountability. Spain already has strong national laws addressing gender pay equity: Royal Decree 902/2020 mandates pay transparency and equal pay for equal work, requiring all companies to maintain a salary register that includes average pay broken down by gender and job category. Companies with 50+ employees must also conduct gender pay audits and implement an Equality Plan, which includes pay equity measures and must be registered with labor authorities. However, the current framework does not yet include like mandatory salary range disclosure in job postings, or an individual employee right to request comparative pay data by gender both of which will be required under the EU Directive. Spain’s Ministry of Equality is expected to propose amendments to existing laws to ensure full alignment with the EU Directive. While Spain is well-positioned due to its existing framework, additional individual rights, reporting duties, and pre-employment disclosures will need to be legislated. Employers should begin preparing now by:

• Reviewing salary structures and job classifications. Spain has already in place a public on-line job evaluation tool.

• Updating recruitment practices to ensure compliance with salary disclosure requirements.

• Training HR teams on how to respond to new employee pay information requests.

The Directive will help close Spain’s current gender pay gap (approximately 9%) and build on the country strong track record of workplace equality.

Sweden

Sweden has long been recognized as a global leader in gender equality and worker rights. A key part of this commitment is reflected in its evolving stance on pay transparency a legal and social framework designed to reduce wage disparities and foster equitable workplace practices. As the European Union advances legislation on pay transparency, Sweden approach provides an instructive model, though Sweden does not currently have a single, unified pay transparency law, but several existing laws and regulations indirectly enforce transparency and seek to eliminate unjustified pay gaps:

1. Discrimination Act (Diskrimineringslagen, 2008:567) This is the cornerstone of gender equality in employment. It requires employers to ensure that there is no unjustified pay difference between women and men performing equal or equivalent work.

2. Pay Surveys (Lönkartläggning) Under the Discrimination Act, employers with at least 10 employees must conduct an annual pay survey. The purpose is to discover, remedy, and prevent unfair pay differences. Employers must also document the process and results when they have 10 or more employees.

3. Sweden relies heavily on collective agreements between trade unions and employers, which often include clauses that enhance pay

   transparency. While not laws per se, these agreements set standards for wages and working conditions in many sectors.

Sweden already meets some of EU directive standards, full alignment with the EU directive will require legislative updates. For example:

• Organisations operating in Sweden will likely already be used to complying with Sweden comprehensive pay transparency rules, given the low headcount threshold.

• However, the Directive will still introduce new requirements in Sweden, including

  (1) the provision of pay information to job applicants;

  (2) the requirement to make objective, gender-neutral criteria used to determine pay, pay levels and pay progression easily accessible;

  (3) a prohibition on pay secrecy clauses in employment contracts; and

  (4) the content of gender pay reports made under the Directive.

• Sweden proposal exceeds the minimum requirements set out in the Directive in some areas. For example, the exemption that may potentially apply to organisations with fewer than 50 workers to make their objective, gender-neutral criteria used to determine pay, pay levels, and pay progression easily accessible is not currently included in Sweden proposal.

The Swedish government is currently assessing how best to incorporate these new EU standards into domestic law. Despite progressive policies, gender pay gaps persist. As of 2023, Sweden unadjusted gender pay gap stands at around 11.2%, slightly below the EU average. Critics argue that:

• Enforcement of existing pay survey requirements is inconsistent.

• Small and medium enterprises (SMEs) face administrative burdens without sufficient support.

• Lack of clear sanctions for non-compliance undermines the effectiveness of the legislation.

Unions and advocacy groups are pushing for more rigorous oversight and automatic penalties for employers failing to conduct or document pay surveys. Sweden’s legal and cultural foundation for pay transparency is strong, rooted in its broader commitment to gender equality. However, with the EU Pay Transparency Directive on the horizon, Sweden is poised for a legislative update that could enhance its frameworks, increase accountability, and further reduce pay disparities. As these changes unfold, Sweden continues to serve as both a pioneer and a work in progress in the pursuit of equal pay for equal work.

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