How Countries Are Implementing the EU Pay Transparency Directive [Updated January 2025]

The EU Pay Transparency Directive was passed into law in June 2023, giving member states three years to implement the new rules. The clock is ticking, and while some countries are yet to start the transposition process, others have already made significant progress. 

We’ve put together this article to help you keep track of the new rules as they emerge in each one of the EU’s 27 member states — we’ll keep it updated as we learn about new legislation. 

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Understanding the Pay Transparency Directive 

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Before we dive into how different countries are implementing the EU Pay Transparency Directive, let’s have a quick refresher on the new rules it will introduce: 

• Pay transparency for jobseekers: Employers will be obliged to provide candidates with a starting salary or range prior to the interview stage. They’ll also be banned from asking candidates about their current or previous salaries. 

• Information rights for employees: Employees will be able to request information about their pay and how it compares to colleagues doing the same work or work ‘of equal value’. They’ll also be able to ask about the criteria used to determine career and pay progression, which must be fair and gender-neutral. Employers will have to provide this information within a reasonable timeframe. 

• Gender pay gap reporting: Employers with over 100 employees will have to report on their gender pay gap every three years, and those with 250+ employees will need to report annually. If a pay gap of 5% or more is uncovered in any job category, they must correct it within six months or carry out a joint pay assessment with workers’ representatives.

• Access to justice for employees: The directive also introduces compensation for workers who have experienced pay discrimination and sanctions for discriminatory employers. Importantly, it shifts the burden of proof from the employee to the employer in pay discrimination cases.

You can learn more about the directive and how it will impact European employers here. 

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Pay transparency directive implementation by country [last updated January 2025]

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The 27 EU member states are not all starting from the same position. Some countries already have pretty extensive pay transparency legislation in place, while others only have broad rules prohibiting pay discrimination based on gender. Below, we’ll discuss the latest information we have on the state of transposition in each country, plus any relevant existing legislation.

Austria 

No transposition activity reported. Existing legislation in Austria includes an obligation to state minimum wages in job vacancy ads, and some reporting requirements for organisations with 50 or more employees. The government has provided an online wage calculator (in German) to help employees determine whether their pay is fair. 

Belgium 

The French Community of Belgium, the Wallonia-Brussels Federation, became the first jurisdiction in the EU to transpose the pay transparency directive in September 2024. The rules apply to entities under the responsibility of the Federation (in other words, public companies). 

They also go beyond the requirements of the directive in a few key ways. For example, they state that employers must inform job applicants of the starting pay or pay range for a position as soon as a job opening is announced (the directive only requires that this information be provided before the interview stage). 

The new rules only partially implement the directive — full implementation will take place at the national level. This will likely mean adapting the country’s existing pay transparency legislation, which already includes reporting obligations for employers with 50 or more employees. 

Bulgaria

No transposition activity reported. 

Croatia 

No transposition activity reported. 

Cyprus 

No transposition activity reported. 

Czech Republic

The directive has not yet been implemented in the Czech Republic. However, the government has set up a working group and is working on draft legislation.

Denmark 

No transposition activity reported. Under current legislation, employers with 35 or more employees must share either gender-segregated wage statistics or an equal pay report with employee groups each year. They are not required to publicly share this information or file it with a regulatory body. 

Estonia

No official transposition activity has been reported in Estonia. However, a digital platform called Pay Mirror (Palagapeegel) is in development. This app is a joint project between Statistics Estonia and the Ministry of Social Affairs, and will enable employers to identify pay gaps and discrepancies based on register data once the directive is implemented. 

Finland

No transposition activity reported. However, the Ministry of Social Affairs and Health has set up a working group to enable a timely transposition. This will likely involve adapting existing legislation, which includes reporting requirements for employers with 30 or more employees.

France

The directive has not yet been transposed in France, though the first draft law is expected in early 2025. This will be an adaptation of the country’s existing pay transparency legislation.

Currently, French organisations with 50 or more employees have to calculate and publish their ‘Equal Pay Index’ (or Egapro index) each year. This is a number between 0 and 100 calculated by scoring the organisation on four or five key metrics depending on the size of the business. 

You can read more about the current state of pay transparency in France in our complete guide. 

Germany

The Federal Ministry for Family Affairs announced that a draft would be published in the second quarter of 2024. However, this deadline was missed and the first draft legislation is now expected in early 2025. 

Transposing the law in Germany will involve adapting existing laws, notably the 2017 Transparency in Wage Structures Act (Entgelttransparenzgesetz or EntTranspG). Under this law, employers in Germany with more than 500 employees have to report regularly on the measures they’re taking to ensure equal pay. Employees of organisations with at least 200 employees can also request certain information on how their pay compares to colleagues. 

Read more about pay transparency in Germany in our guide. 

Greece

No transposition activity reported. 

Hungary

No transposition activity reported. 

Ireland

No transposition activity reported. Under current legislation, organisations with 150+ employees are required to report annually on their mean and median pay and bonus gaps, and the proportion of men and women that receive bonuses. This will be extended to companies with at least 50 employees from 2025. 

Italy

No transposition activity reported. Currently, Italian employers with at least 50 employees must report on gender and pay data every two years. The country also has a gender equality certification scheme used to demonstrate which companies are taking significant measures to reduce the gender pay gap. 

Latvia

No transposition activity reported. Mandatory wage transparency in job ads was introduced in Latvia in 2018. However, there are currently no reporting requirements for employers, so the directive will be a big change. 

Lithuania

No transposition activity reported. Under existing legislation, employers must include salary ranges in job descriptions. There are also some reporting requirements for companies with 20 or more employees. 

Luxembourg

No transposition activity reported. There are currently no reporting requirements, but employers with 50 or more employees are required to provide employee representatives with certain sex-disaggregated statistics on a biannual basis. The Ministry of Equality Between Men and Women (MEGA) has also developed an online tool that helps employers identify the causes behind any pay gaps.

Malta 

No transposition activity reported. 

Netherlands

The directive has not yet been transposed in the Netherlands. However, a bill that would require gender pay gap reporting has been under discussion since 2019. If it passes, the new law will require companies with 50 or more employees to provide annual gender pay gap data to their works council. It would also give employees new information rights about gender pay gaps and create a new certification system to monitor compliance. 

Poland

No transposition activity reported. 

Portugal

No transposition activity reported. Under the current rules, state-owned and publicly traded companies must prepare an annual equality plan with the objective of achieving equal pay between men and women. They must present an action plan for assessing any pay differences to the Inspectorate Service of the Ministry of Labour, Solidarity and Social Security, and implement the plan within one year. 

Romania

No transposition activity reported. Under current law, employees’ salaries are confidential and employees are bound by strict confidentiality agreements. The implementation of the pay transparency directive will therefore represent a big cultural shift for Romanian employers and employees.  

Slovakia

No transposition activity reported. 

Slovenia

No transposition activity reported. 

Spain

No transposition activity reported. Existing legislation was passed in 2021, and requires companies with more than 50 employees to conduct regular remuneration audits (this is voluntary for smaller employees). Companies of all sizes must keep a remuneration register of aggregated and disaggregated pay data for all employees. Employees can access the register through a workers’ representative or union member.

Sweden

In May 2024, Sweden became the first government to publish draft legislation implementing the EU pay transparency directive. This takes the form of a series of amendments to the existing Discrimination Act (Diskrimineringslagen), which is already broadly in line with the directive. 

Sweden has a strong history as a leader in equality, and its culture is broadly favourable to pay transparency. The draft legislation shows that Sweden plans to go above and beyond the requirements of the directive in several key ways. For example, in addition to salary information, employers must provide job candidates with the collective agreement provisions that apply to a role before the salary negotiation process. 

However, the biggest difference between the directive and Sweden’s proposed legislation is the scope of the reporting requirements.  Only companies with 100+ employees are within the scope of this part of the directive, but Sweden intends to maintain its current reporting requirements, which apply to all companies with 10 or more employees.

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Preparing for implementation: what employers can do now

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If the new pay transparency rules are not yet in force in your country, they soon will be. And preparing for the changes now can help ensure you’re ready to comply when they do come in. So, what should you be doing to prepare for the new pay transparency legislation? Read our full guide for the details. 

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More insights on pay transparency in Europe 

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Want more information on the implementation of the pay transparency directive? Watch this space: we’ll be updating this blog post regularly to incorporate the latest regulatory changes. 

In the meantime, you can learn more about the state of pay transparency in Europe by sticking around on this blog. Here are a few posts from our archive to get you started: 

• 5 Barriers to Pay Transparency (And How to Overcome Them)
• Building a Business Case for Pay Transparency: 6 Steps to Follow
• The Clock is Ticking on Pay Transparency: Here's How to Prepare
• EU Pay Equity Directive: What Employers Need to Know
• Exploring Pay Transparency Legislation Around the World

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