![How Countries Are Implementing the EU Pay Transparency Directive [Updated June 2025]](https://cdn.prod.website-files.com/67d7e1e2f12d2942bb8d0309/6800da19bf0ad5c3d89c6d56_67e2c2cbef618bc98559ce0c_679b9fd8dac8fc3762b7e816_General%252520Topic.avif)
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.
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 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 June 2025]
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, but the Ministry of Economic Affairs is expected to produce draft legislation by summer 2025. 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.
The legislation also 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
The directive has not yet been transposed in France. However, the Minister of Labour made an announcement confirming several key points in May 2025. Most crucially, she confirmed that the government would like to move quickly with the implementation and expects to have draft legislation on the table by September 2025.
The minister also confirmed that the implementation of the directive would involve redesigning the existing ‘Equal Pay Index’ (or Egapro index), which requires employers to publish certain key statistics each year. The government plans to adjust these metrics to align them with the directive, and introduce a tool to automate reporting.
The French government hasn’t yet confirmed what sanctions for non-compliance will look like, but has suggested they will be designed to have a ‘dissuasive effect’, so we can expect them to be significant.
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
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 that receive bonuses. This will be extended to companies with at least 50 employees from 1 June 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
In May 2025, Lithuania published a draft bill partially transposing the directive. 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.
If approved, the proposed legislation will supplement Lithuania’s existing laws, which already require employers to provide salary ranges for open jobs and prohibit them from asking about past salaries. Lithuania also already has pay gap reporting requirements for companies with 20 or more employees, and requires employers to take corrective action if a gap of 5% or more is found. This is all already in line with the requirements of the directive.
Luxembourg
No official transposition activity has been reported, but there’s an indication that preparation is underway. 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
No transposition activity reported.
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.
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.
Poland
On 5 December 2024, a group of Polish members of parliament submitted a draft law that would partially implement the directive. This is not yet a formal governmental initiative, but it is a first step towards implementation. The draft law focuses on the pay transparency provisions of the directive and does not cover gender pay gap reporting obligations.
The draft bill is broadly in line with the provisions of the directive, and goes beyond its requirements in a few places. For example, the bill would require employers to share salary information in job postings, whereas the directive only requires this information to be shared before the interview stage. The Polish draft bill also shortens the time employers would have to respond to employee requests for pay information from two months to 14 calendar days.
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, but there is an indication that draft legislation is in process. 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
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
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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