How Countries Are Implementing the EU Pay Transparency Directive [Updated September 2026]

The EU Pay Transparency Directive entered into force in June 2023, giving member states three years to implement the new rules. That deadline has now passed, and implementation remains uneven across the EU. 

Four countries met the 7 June deadline for implementation: Slovakia, Italy, Lithuania and Malta. Greece has since completed transposition, while Estonia has partially introduced the Directive into national law. Most other member states are still progressing through draft, consultation or preparatory stages.

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. 

Understanding the Pay Transparency Directive 

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 introduces: 

• Pay transparency for jobseekers: Employers must provide candidates with the initial salary or salary range early enough to support an informed and transparent pay negotiation — for example, in the job advertisement or before the interview. They are also banned from asking candidates about their current or previous salaries.
• Information rights for employees: Employees have the right to request information about their pay and how it compares to colleagues doing the same work or work ‘of equal value’. They can also ask about the criteria used to determine career and pay progression, which must be fair and gender-neutral. Employers must provide this information within a reasonable timeframe. Employers must also make the criteria used to determine pay, pay levels and pay progression easily accessible, and these criteria must be objective and gender-neutral.
• Gender pay gap reporting: Employers with 250+ employees must report on their gender pay gap annually from 2027; those with 150–249 employees report every three years from 2027, and those with 100–149 employees follow the same three-year cycle starting in 2031. If an unjustified 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 strengthens employees’ position in pay discrimination cases: once a worker establishes facts that give rise to a presumption of discrimination, it is generally up to the employer to prove that no pay discrimination occurred.

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

Pay transparency directive implementation by country [last updated September 2026]

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

Austria has not yet completed transposition of the Pay Transparency Directive. However, an implementation draft has now been prepared: in June 2026, Labour Minister Korinna Schumann presented a proposal and sent it into the government’s political coordination process. No final legislation has yet been adopted.

Existing Austrian legislation already requires employers to state the applicable minimum pay in job vacancy advertisements. Employers with 150 or more employees must also prepare an income report every two years, and the government provides an online wage calculator to help employees assess typical pay levels.

Belgium 

Belgium has partially transposed the Directive, but not yet at federal level. 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 public sector employees within the remit of the Federation.

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.

At federal level, Belgium has not yet fully transposed the Directive. In January 2026, the House of Representatives issued a resolution proposal calling on the federal government to move ahead with implementation, and the Flemish Government has also approved a proposal covering certain public entities under its jurisdiction. However, shortly before the 7 June 2026 deadline, Belgium requested a six-month extension from the European Commission. Further clarification is expected on whether this delay will be accepted and how federal rules will apply to private-sector employers.

Bulgaria

Bulgaria has now published draft legislation to transpose the Pay Transparency Directive. The draft was released in May 2026 and opened for consultation until 2 June 2026, shortly before the EU transposition deadline.

The draft introduces core Directive requirements, including pay information rights for employees, pay transparency obligations for employers and gender pay gap reporting. It also expands the role of Bulgaria’s equality enforcement framework, including the Commission for Protection against Discrimination. The legislation is still in draft form, so the final scope and timing may change.

Croatia 

No transposition activity reported. Croatia has missed the June 2026 deadline for implementation. 

Cyprus 

A draft transposition bill was published in November 2025 and a revised version followed in January 2026. However, Cyprus did not complete transposition before the June deadline, and no final legislation has yet been adopted. The proposal remains pending following the 2026 parliamentary elections.

Czechia

Czechia has already implemented a small part of the Directive into national law. An amendment to the Czech Labour Code, effective from 1 June 2025, introduced a ban on pay secrecy clauses in employment documentation. Employers who fail to comply with this rule could face fines of up to CZK 400,000 (around EUR 16,000).

The Ministry of Labour and Social Affairs presented draft legislation covering the remaining requirements in March 2026, followed by a revised draft in July. On 31 August 2026, the Czech government formally approved the proposal, moving the legislation another step forward.

The proposal includes measures such as a ban on salary-history questions, advance pay information for candidates and gender pay gap reporting for larger employers. Final legislation still needs to complete the parliamentary process, so Czechia remains behind the EU transposition deadline.

Denmark 

Denmark has now taken a formal step toward transposing the EU Pay Transparency Directive. On 26 February 2026, the government published a consultation draft bill amending the Equal Pay Act, confirming that the legislative process is now underway.

The draft would implement the Directive through Denmark’s existing equal pay framework. According to the consultation materials, the law is expected to enter into force on 1 January 2027, after the EU’s 7 June 2026 transposition deadline.

Denmark already has some reporting obligations in place for employers with 35 or more employees, but the new legislation would introduce broader transparency and enforcement measures in line with the Directive.

Estonia

Estonia has now partially transposed the Pay Transparency Directive. Amendments to the Employment Contracts Act entered into force on 13 July 2026 and introduce several recruitment-stage transparency requirements.

Employers must provide candidates with information about the salary or salary range before a job interview, may no longer ask applicants about their previous pay and cannot prevent employees from disclosing their own salary.

However, Estonia has not yet implemented the Directive in full. Significant elements, including the broader reporting framework, remain outstanding, and the government has sought additional time for these requirements. Estonia is also continuing work on Pay Mirror (Palagapeegel), a digital tool intended to help employers analyse pay gaps.

Finland

Finland missed the 7 June 2026 transposition deadline, but its implementation process has moved forward. On 9 July 2026, the government formally submitted legislation to Parliament to transpose the Pay Transparency Directive.

The proposal would amend Finland’s existing equality legislation and introduce new rights and obligations around pay information, recruitment transparency and gender pay gap reporting. The government is aiming for the legislation to enter into force on 1 January 2027.

The proposal remains subject to parliamentary consideration, so the final text may still change.

France

France is preparing legislation to transpose the EU Pay Transparency Directive but has missed the June 2026 deadline. The proposed framework would replace the current Gender Equality Index with broader pay transparency obligations.

The proposal retains the 50-employee threshold for certain reporting duties, introduces salary transparency in recruitment, expands employee pay-information rights and adds new indicators for pay-gap disclosure. A revised version of the bill was submitted to the Conseil d’État in June 2026 following consultation with social partners.

The government is now due to present the bill to the Council of Ministers on 9 September 2026, before parliamentary consideration later in the year. Adoption could extend into early 2027, with some obligations expected to be phased in later.

You can read more about the most recent draft law in France in our complete guide for comp professionals. 

Germany

In July 2025, German officials announced the creation of a formal Commission to begin implementing the Pay Transparency Directive. The Commission includes experts from business associations, social partners, the German Trade Union Confederation (DGB) and the Confederation of German Employers’ Associations (BDA). In November 2025, the Commission published its final report setting out recommendations for how to transpose the Directive, and the government is now preparing draft amendments to the existing Transparency in Wage Structures Act. Germany has not yet completed transposition. The government is expected to present draft amendments in 2026, after which the legislative process will begin.

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

Greece has now transposed the Pay Transparency Directive into national law. Law 5316/2026 was published on 6 July 2026, shortly after the EU transposition deadline.

The legislation introduces a comprehensive framework covering recruitment-stage pay transparency, employee information rights, gender pay gap reporting, joint pay assessments, enforcement and remedies.

Some provisions took effect when the law was published. The main employer pay-transparency obligations — including objective pay structures, recruitment transparency, information rights and reporting — will apply from 1 November 2026.

Learn more about the Greek law in our full guide for comp professionals. 

Hungary

No transposition activity reported. Hungary has missed the June 2026 deadline for implementation. 

Ireland

Ireland has not yet transposed the Pay Transparency Directive. Recruitment-stage measures originally included in the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 — including salary information for candidates and a ban on salary-history questions — are now expected to be taken forward through a separate Pay Transparency Bill.

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Ireland missed the 7 June 2026 deadline. The government has indicated that implementation will proceed on a phased basis once legislation is passed, while the broader pay-transparency and reporting framework is still being developed.

Italy

Italy has transposed the Pay Transparency Directive into national law. Legislative Decree No. 96 of 7 May 2026 was published in the Official Journal on 1 June 2026 and entered into force on 7 June 2026, in line with the Directive’s deadline.

The decree broadly follows the Directive. It introduces salary-range transparency, gives employees the right to ask for information about pay criteria and pay levels, and requires employers to remind employees of this right every year. It also introduces gender pay gap reporting, with the first reports for larger employers expected from June 2027.

Italy has also made some specific choices in how it applies the Directive. For example, employees will only be able to request pay information once per year, and employers will have two months to respond. The decree also defines “pay levels” more narrowly for employee information requests, focusing on fixed and continuous pay rather than variable or discretionary elements.

Read more about Italy’s pay transparency law and what it means in practice in our complete guide. 

Latvia

Latvia has published draft legislation to transpose the Pay Transparency Directive. The draft law, available on the state legislative portal, sets out the core framework for implementation, including requirements for gender-neutral pay criteria, employee rights to pay information, employer reporting obligations, and enforcement measures.

The draft broadly follows the Directive’s reporting thresholds and timelines. It also uses some of the flexibilities the Directive allows, including making reporting voluntary for employers with fewer than 100 employees and allowing employers with fewer than 50 employees to provide pay progression criteria on a voluntary basis. The legislative process is still ongoing, so the final scope and requirements may change before adoption.

Lithuania

Lithuania has now transposed the Pay Transparency Directive into national law. The final legislation was adopted in 2026 and most requirements entered into force on 7 June 2026, in line with the Directive’s deadline.

The new rules build on Lithuania’s existing framework, which already requires salary ranges in job advertisements, prohibits salary-history questions and includes pay gap reporting requirements for employers with 20 or more employees. The legislation also requires employers to maintain pay structures based on objective, gender-neutral criteria and expands employee rights to pay information.

Some obligations will apply later. Current updates indicate that the right-to-information provisions will apply from 1 January 2027, with the first reporting deadline expected in 2028.

Read more in our full guide to pay transparency in Lithuania. 

Luxembourg

Luxembourg has not yet published a transposition bill, but implementation work is underway. The Ministry of Labour has prepared a preliminary draft, which is currently undergoing interministerial consultation before being presented to the social partners.

There are currently no gender pay gap 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 

Malta has now fully transposed the Pay Transparency Directive. Legal Notice 173 of 2026 — the Equal Pay (Transparency and Reporting) Regulations, 2026 — was published in the Government Gazette on 5 June 2026 and introduced the remaining pay transparency and reporting requirements.

This follows Malta’s earlier 2025 legislation, which had partially implemented the Directive by giving job applicants the right to receive pay information before the start of employment and giving employees certain pay-information rights. The 2026 regulations complete the framework by adding broader transparency and reporting obligations in line with the Directive.

Netherlands

The Dutch government published draft legislation to implement the Pay Transparency Directive in March 2025, proposing amendments to the existing Equal Treatment for Men and Women Act. The draft broadly follows the Directive, covering equal pay for work of equal value, reporting obligations, employee information rights and a reversed burden of proof in pay discrimination cases.

The bill was submitted to the House of Representatives on 21 May 2026 after review by the Council of State. The government has also begun consulting on secondary legislation covering areas such as pay-reporting definitions, calculation methods, templates and data requirements.

The Netherlands did not meet the 7 June 2026 transposition deadline. The current proposal continues to point to a 1 January 2027 entry into force.

Poland

Poland has already introduced some pay transparency measures through Labour Code amendments that took effect on 24 December 2025. These changes focus on recruitment-stage transparency, including clearer pay information for candidates and gender-neutral job titles.

A broader bill is being prepared to implement the remaining elements of the Directive. Poland published an initial draft in December 2025 and a revised version dated 29 April 2026. The updated text clarifies several areas, including the definition of pay, criteria for assessing work of equal value, treatment of temporary workers, competent authorities and maximum penalties for non-compliance. The bill remains under legislative review and will only take effect six months from promulgation. This means that Poland did not meet the June 2026 deadline.

Portugal

Portugal has now published draft legislation to partially transpose the Pay Transparency Directive. The government released its proposal on 5 August 2026, after missing the EU’s June transposition deadline, and opened it for public consultation until 25 August.

The proposal would strengthen Portugal’s existing equal-pay framework by introducing additional requirements around transparent and gender-neutral pay policies, employee information rights and gender pay gap reporting. In some areas it goes beyond the Directive’s minimum requirements, including by extending certain reporting obligations to employers with 50 or more employees.

The proposal represents only partial transposition, so further measures will still be required before Portugal has fully implemented the Directive.

Romania

Romania’s transposition process has moved into Parliament. Following the publication of draft legislation earlier in 2026, a legislative proposal on pay transparency was formally registered with the Senate and is now proceeding as L445/2026.

The proposal is being considered under an emergency procedure and has been referred to the relevant Senate committees. It broadly aims to implement the Directive’s rules on equal pay, recruitment transparency, employee information rights, reporting and enforcement.

Romania has not yet adopted final legislation, so further amendments remain possible as the bill moves through Parliament.

Slovakia

Slovakia became the first EU member state to complete nationwide transposition of the Pay Transparency Directive. Parliament adopted the Equal Pay Act on 15 April 2026, and the law entered into force on 7 June.

The legislation introduces salary-range transparency, bans salary-history questions, expands employee information rights and establishes gender pay-gap reporting obligations for employers with 100 or more employees.

Since the legislation took effect, the Ministry of Labour has also published methodology and an analytical tool to support employers with job evaluation, pay structures and implementation of the new rules.

Read about the Slovak law in detail in our complete guide. 

Slovenia

The Ministry of Labour, Family, Social Affairs and Equal Opportunities has set up working groups and is drafting legislation. Further clarification is expected on the adoption timeline.

Spain

Spain has now published draft legislation to partially transpose the Pay Transparency Directive. The Ministry of Labour released a draft Royal Decree on 3 August 2026, with public consultation running until 24 August.

The proposal builds on Spain’s existing remuneration registers, equality plans and pay audits. Among other measures, it would introduce additional employee information rights and expand gender pay gap reporting, including to some employers below the Directive’s 100-employee threshold.

However, the draft does not currently address every requirement of the Directive, including some recruitment-stage transparency provisions. Further changes or additional legislation may therefore be required before Spain completes transposition.

Sweden

Sweden had been one of the earliest movers on transposition, becoming the first country to publish draft legislation in May 2024. However, its position shifted significantly in March 2026, when the government announced that it wanted the Directive’s implementation postponed and its requirements reconsidered at EU level.

The government has not moved forward with a transposition bill. In June 2026, it instructed the Equality Ombudsman to continue preparatory work and report back by November 2027.

The European Commission has since confirmed that member states cannot unilaterally postpone the implementation of an adopted Directive. It has also said that it does not plan to include the Pay Transparency Directive in a future regulatory simplification package or introduce a “stop-the-clock” measure. Sweden therefore remains legally required to transpose the Directive despite its delayed national timetable.

Preparing for implementation: what employers can do now

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. 

More insights on pay transparency in Europe 

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: 

• Pay Transparency Directive: A Guide for Employers by 2026
• EU Gender Pay Gap Reporting: A Helpful Guide for 2026
• Practical Guide to EU-Compliant Salary Ranges in Job Ads
• 5 Pay Transparency Challenges for Managers (And How to Overcome Them)
• How Systemic Undervaluation Creates Hidden Pay Gaps Across Job Families