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The EU Pay Transparency Directive entered into force 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. As yet, no member state has fully transposed the Directive.
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 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 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 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.
Pay transparency directive implementation by country [last updated April 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
No draft transposition bill has yet been published. 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 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 (the Directive only requires that this information be provided before the interview stage).
As of early 2026, there is still no federal draft law fully transposing the Directive. However, in January 2026, Belgium’s House of Representatives issued a resolution proposition calling on the federal government to move ahead with nationwide transposition of the Directive, signalling growing legislative momentum. And, on 13 March 2026, the Flemish Government approved a proposal to transpose certain requirements for public entities under its jurisdiction.
Bulgaria
No transposition activity reported. There is still no draft legislation or formal government announcement, beyond the general obligation to transpose by June 2026.
Croatia
No transposition activity reported.
Cyprus
A draft transposition bill was published in November 2025, following preparatory work that included setting up a tripartite technical committee to review draft work on the harmonisation bill. The bill is now moving through the legislative process (including review and approval steps involving the Council of Ministers and Parliament).
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).
On 16 March 2026, the Ministry of Labour and Social Affairs presented draft legislation to transpose the rest of the Directive. The draft would ban salary-history questions, require employers to disclose pay ranges in advance, and introduce gender pay gap reporting for larger employers. The core rules are expected to take effect from 1 January 2027, with reporting obligations phased in from 2028 onwards, meaning Czechia will implement the Directive after the EU 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, which would be later than 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
No official transposition activity has been reported in Estonia. The Ministry of Economic Affairs was expected to produce draft legislation by summer 2025, but no updates have been reported so far. In the meantime, 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
Finland’s Ministry of Social Affairs and Health working group published draft legislation that largely aligns with the Directive’s minimum requirements in May 2025. It includes a requirement for employers with at least 50 employees to share information on their pay criteria, and introduces reporting requirements for companies with 100 or more employees. In December 2025, the Ministry of Social Affairs and Health requested formal stakeholder statements on the draft government proposal, with comments due in early February 2026. The government now expects the final legislation to enter into force on 18 May 2026, assuming parliamentary approval on schedule.
In addition to reporting requirements, the legislation prohibits employers from asking about salary history and requires them to share salary information with candidates before pay negotiations. However, although it suggests including this information in job postings, it doesn’t make this a requirement. Lastly, the draft legislation sets fines for noncompliance ranging from €5,000 to €80,000, depending on the severity of the case.
The proposed new rules are open to revision and may undergo changes before implementation. Some employer groups have raised problems, arguing that the draft legislation is legally flawed and goes beyond the requirements of the Directive. They have raised concerns that the legislation, if approved, would undercut competition and represent an unreasonable administrative burden on Finnish employers.
France
France is preparing legislation to transpose the EU Pay Transparency Directive. In March 2026, the Ministry of Labour circulated a draft bill to unions and lawmakers outlining how the Directive could be implemented in national law.
The proposal is expected to build on France’s existing Gender Equality Index, expanding the framework to align with the Directive’s transparency and reporting requirements. Early reporting indicates the draft may extend some obligations to employers with 50 or more employees, introduce additional reporting indicators, and require salary ranges in job postings.
The draft is currently being discussed with social partners and may evolve during the legislative process before being submitted to Parliament. A further consultation meeting is scheduled for mid-March 2026. France is still working toward transposition, but the latest reporting suggests it is increasingly unlikely to meet the 7 June 2026 deadline.
You can read more about the current state of pay transparency in France in our complete guide.
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. The exact implementation date is pending, but 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
No draft legislation has been published, but the Greek government has established a working group for transposition.
Hungary
No transposition activity reported.
Ireland
On 15 January 2025, Ireland became the fourth European country to initiate implementation of the Directive, through the General Scheme of the Equality (Miscellaneous Provision) Bill 2024.
This bill contains two provisions that partially implement the Directive. First, it introduces a ban on asking candidates about their salary history. It also requires employers to share salary information in their job advertisements. This goes beyond the provisions of the Directive, which only require this information to be provided before the interview stage.
The bill doesn’t include provisions for the gender pay gap reporting portion of the Directive. However, the country does already have reporting requirements in place. 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 who receive bonuses. This was extended to include companies with at least 50 employees from 1 June 2025.
Italy
Italy has now published draft transposition legislation, and in early February 2026 the Council of Ministers gave initial approval to a draft implementing decree, signalling that the formal legislative process is underway.
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
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
In May 2025, Lithuania published a draft bill partially transposing the Directive. This was later updated, and an official draft was registered on 12 September 2025. The legislation gives employees the right to request information about their pay level and how it compares to that of other employees doing the same or similar work. It also requires employers to develop pay structures based on gender-neutral factors, and implements a ban on asking job candidates about their previous salaries during the hiring process.
The transposition process moved forward in March 2026, when the government approved the latest implementation proposals. If adopted, the legislation will build on Lithuania’s existing framework, which already requires employers to include salary ranges in job advertisements and prohibits salary-history questions. Lithuania also has established pay gap reporting requirements for employers with 20 or more employees, including an obligation to take corrective action where a pay gap of 5% or more is identified, meaning many of the Directive’s core principles are already in place.
Luxembourg
Luxembourg is still preparing its transposition of the Pay Transparency Directive, but no draft bill has yet been published. That means the process appears to have moved more slowly than earlier signals, which suggested a draft might be ready by the end of 2025.
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
The Maltese government released draft legislation partially implementing the Directive in June 2025 and the new rules entered into force on 27 August 2025. Under the law, employers must provide pay information to job applicants before the start of employment. However, it doesn’t go as far as some other countries: there’s no requirement to include salary in job ads, and no explicit ban on asking candidates about salary history (a core requirement of the Directive).
Similarly, the legislation gives employees the right to request information about their pay level and the pay levels of colleagues performing the same work. However, it does not extend this right to information about colleagues performing ‘work of equal value’, a key principle of the EU Directive. The law also contains no requirement for gender pay gap reporting. This will need to be introduced by further legislation before the June 2026 deadline.
Netherlands
The Dutch government published draft legislation to implement the Pay Transparency Directive in March 2025. Instead of introducing a new law, the draft proposes amendments to the existing Equal Treatment for Men and Women Act, bringing it in line with the demands of the Directive. In January 2026, the draft was submitted to the Council of State for review, a key procedural step before it can progress through parliament.
The bill is more or less a clean transposition of the Directive, covering equal pay for work of equal value, gender pay gap reporting obligations and employee information rights. It also specifies that the burden of proof in pay discrimination cases should fall on employers, who have to justify that any discrepancy in pay is not due to the employee’s gender.
One difference in the Dutch law is that reporting obligations will apply to employers with 100+ employees (the Directive only makes this a requirement for those with a headcount of 150 or more). The draft also contains additional provisions concerning the treatment of temporary workers.
However, there is now some doubt as to whether the Netherlands will meet the June 2026 implementation deadline. In September 2025, the government announced that implementation would be delayed until January 2027. The EU Commission has rejected this postponement, stressing that all countries must implement the new rules by June 2026. It is not yet clear what the consequences will be for missing the deadline.
Poland
Poland has already introduced some pay transparency measures through Labour Code amendments that took effect in December 2025. These changes mainly focus on recruitment-stage transparency, requiring employers to provide clearer pay information to candidates earlier in the hiring process.
Additional legislation is now being prepared to implement the rest of the EU Pay Transparency Directive. In December 2025, the government published a draft bill on the official legislative portal covering the remaining elements of the Directive, including broader transparency requirements and pay gap reporting obligations. The draft is currently progressing through the legislative process and may be further refined before final adoption.
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
Romania has now published draft legislation to transpose the Pay Transparency Directive, with the consultation period running until 8 April 2026. The draft broadly mirrors the structure of the Directive and would apply across both the public and private sectors.
In several places, the Romanian draft is more prescriptive than the Directive. For example, reporting on the draft notes tighter deadlines around employee information requests and the handling of unjustified pay gaps. The bill is still at consultation stage, so further legislative clarification is expected.
Slovakia
Slovakia has published a draft Equal Pay Act, fully transposing the Directive. It introduces salary-range transparency, bans salary-history questions, expands employee information rights and requires gender pay-gap reporting for employers with 100+ staff. The law was formally submitted to parliament in January 2026 and is expected to enter into force on 1 June 2026.
Slovenia
Slovenia has begun preparations to transpose the Directive. The Ministry of Labour, Family, Social Affairs and Equal Opportunities has set up working groups and is drafting legislation, which is expected to be adopted soon.
Spain
No draft legislation has yet been published. Government and expert commentary suggest that transposition work is at an early, informal stage, and no short-term implementation timetable has been announced, even though Spain already has extensive pay-transparency rules dating from 2021.
Under these rules, companies with more than 50 employees must conduct regular remuneration audits (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
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. The government first signalled that it wanted more time, proposing that the implementing legislation should enter into force on 1 January 2027 and that the first reports should be submitted in May 2028.
It then went further, announcing that it wanted the Directive’s implementation date postponed and the Directive itself renegotiated in a less burdensome direction. The government also said that, for now, it does not intend to submit a bill to parliament. This means Sweden has moved from early draft legislation to an openly delayed and politically contested implementation path.
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:
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