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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 of our latest update, Slovakia has become the first EU member state to complete nationwide transposition, while 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 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 100 or more 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 May 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).
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. However, there is still no federal draft law fully transposing the Directive.
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
Estonia has not yet published a full transposition bill. Earlier work focused on preparing supporting tools, including an online platform called Pay Mirror (Palagapeegel), which is intended to help employers identify pay gaps using register data.
However, Estonia’s position shifted in April 2026, when the government signalled that it would seek to postpone implementation and push for changes to the Directive at EU level. Estonia is now expected to miss the 7 June 2026 transposition deadline. The government has said it would be willing to pay fines for missing the deadline rather than subject businesses to the “administrative burden” the Directive will represent.
Finland
Finland’s Ministry of Social Affairs and Health working group published draft legislation in May 2025 that broadly follows the Directive’s minimum requirements. It would require employers with at least 50 employees to disclose pay criteria and introduce reporting obligations for companies with 100 or more employees. The draft also includes a salary-history ban, pre-negotiation salary information for candidates and fines of up to €80,000 for noncompliance.
In December 2025, the Ministry opened a formal consultation on the draft government proposal. The text remains subject to revision and has drawn criticism from employer groups over legal clarity, scope and administrative burden.
Finland had previously expected the legislation to enter into force on 18 May 2026, but that timeline has slipped. Recent updates indicate that the final government proposal has been delayed again and that the legislation is unlikely to come into force before the end of 2026 at the earliest. This means Finland will not meet the 7 June 2026 transposition deadline.
France
France is preparing legislation to transpose the EU Pay Transparency Directive, but is now expected to miss the June 2026 deadline. In March 2026, the Ministry of Labour circulated a draft bill setting out a new framework that would replace the current Gender Equality Index with broader pay transparency obligations.
The proposal would retain the 50-employee threshold for certain reporting duties, introduce salary ranges in job postings, expand employee pay-information rights and add new indicators for pay-gap disclosure. Mandatory consultations are continuing through spring 2026, with State Council review and parliamentary consideration expected later in the year.
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
Ireland began implementing parts of the Directive through the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024. The proposal would ban salary-history questions and require employers to publish salary information in job advertisements, going beyond the Directive’s minimum recruitment-stage requirement.
However, Ireland has now confirmed that it will not fully transpose the Directive by the 7 June 2026 deadline. The government has indicated that implementation will instead proceed on a phased basis, while the broader legislative package — including additional pay-transparency and reporting obligations — is still being developed.
Italy
Italy approved its implementing decree on 30 April 2026. Once signed and published, the new rules are expected to apply from 7 June 2026, in line with the Directive’s deadline.
The decree broadly follows the Directive. It will introduce salary ranges in job ads, give employees the right to ask for information about pay criteria and pay levels, and require employers to remind employees of this right every year. It will also introduce 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.
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. 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 if Malta is to meet the June 2026 deadline.
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 draft was submitted to the Council of State in January 2026, and the Council issued its advice in April. On 21 May 2026, the bill was submitted to the House of Representatives, together with a further report responding to the Council of State’s opinion.
Despite this progress, the Netherlands is expected to miss the 7 June 2026 transposition deadline. The current proposal points to a 1 January 2027 entry into force, and the Council of State has advised the government to explain the risks of late implementation more clearly.
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 will miss the June 2026 deadline.
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 published draft legislation to transpose the Pay Transparency Directive in March 2026, with the consultation period running until 8 April. The draft broadly follows 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.
However, this process may now be delayed. Romania’s government collapsed in May 2026, which could slow progress on the bill and make implementation by the 7 June 2026 deadline less likely.
Slovakia
Slovakia has become 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 was subsequently signed and promulgated in May.
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. The law is due to enter into force on 7 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
On 24 April 2026, the Ministry of Labour and Social Economy opened a public consultation on a future Royal Decree intended to implement the Directive, with submissions accepted until 8 May 2026.
Spain already has relatively extensive pay-transparency rules dating from 2021, including remuneration registers and remuneration audits for larger employers. The new initiative is expected to build on that framework, but the legislative text has not yet been published and further clarification is expected.
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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