European Pay Transparency Directive Tracker
Austria
No public legislative activity reported. Only minor adjustments expected given Austria's existing equal pay framework in place since 2011.
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Belgium
Last update: April 2026 — Belgium remains a jurisdictional patchwork.
Flemish public sector: the draft decree adopted by the Flemish Government in November 2025 is now confirmed to enter into force on June 7, 2026 — the EU deadline. The decree covers Flemish services, local Flemish authorities, and certain educational institutions, applying to all workers regardless of employment relationship type.
Wallonia-Brussels Federation: decree in force since September 2024, covering only French-speaking public-sector employers in that region.
Federal private-sector draft: "expected to circulate shortly" per April 2026 legal analyses, but no public text yet available. The January 2026 House of Representatives resolution proposition called for minimal transposition.
Belgium will therefore enter June 2026 with regional public-sector laws in force in Flanders and Wallonia-Brussels, but no federal private-sector framework. Belgian private-sector workers will be able to rely on the directive's direct effect from June 7, 2026.
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Bulgaria
Status: Draft legislation published. Bulgaria published a draft transposition law in May 2026 (an amendment to the Anti-Discrimination Act), open for public consultation until 2 June 2026. Its self-imposed 29 May 2026 National Assembly adoption target passed with no bill tabled and no public communication, so Bulgaria misses the 7 June 2026 deadline.
Direct effect applies from 7 June 2026: employees and job applicants in Bulgaria can rely on the directive against their employer for sufficiently precise and unconditional provisions, regardless of whether Bulgarian law is in force.
Bulgaria remains one of the EU Member States most exposed to infringement proceedings on the pay transparency file.
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Croatia
No public activity or draft law reported.
No specific pay transparency laws currently in force.
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Cyprus
Comprehensive draft bill published January 26, 2026. Cyprus goes beyond directive minimums in several areas: broad definition of "pay" covering all cash and in-kind benefits, enhanced job evaluation requirements with explicit weighting of gender-neutral criteria, strong enforcement including labour inspector investigative powers, fines, and criminal liability.
Full transposition targeted for June 7, 2026. The National Gender Equality Strategy 2024-26 confirms implementation is underway.
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Czech Republic
Last update: March 26, 2026 — The Ministry of Labour and Social Affairs (MPSV) published a draft amendment to the Labour Code transposing Directive 2023/970 for public consultation.
Explicit "minimalist transposition" approach. The Czech Republic will miss the June 7, 2026 deadline — entry into force is targeted for January 1, 2027, with reporting phased later.
Unique feature: the Czech Ombudsman (Veřejný ochránce práv) acts as a privacy intermediary in cases where sharing pay data could reveal individual compensation — a mechanism no other Member State has proposed.
Reporting: annual from 2028 for 250+ employees (using 2027 data), triennial from 2028 for 150–249, triennial from 2031 for 100–149.
Pay-secrecy clause ban effective since June 1, 2025 via an earlier Labour Code amendment.
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Denmark
Denmark held a general election on March 24, 2026, adding significant political uncertainty to the transposition process. The Social Democrats won the most seats (38) but at their lowest vote share since 1903 (21.9%). Neither the red nor blue bloc secured a majority, with coalition negotiations ongoing since March 25.
A draft bill implementing the Pay Transparency Directive was published for public consultation on February 26, 2026, with the consultation period closing March 27. The proposed effective date is January 1, 2027. The new parliament will need to restart the legislative process, adding further delay.
Key provisions in the Danish draft: salary range disclosure to job applicants; reporting obligations for employers with 100+ employees; broader scope extending to employers with 50+ employees where there are at least 8 employees of each gender in the same job category; first reporting due September 2028.
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Estonia
UPDATE — April 16, 2026: Estonia's Economic Affairs Minister Erkki Keldo announced that the government would rather pay European Commission infringement fines than transpose the directive in its current form, citing prohibitive compliance costs ("millions of euros and thousands of working hours" of business burden). A subsequent statement walked the position back slightly, but Estonia's posture is now clearly aligned with Sweden's: delay, renegotiate, accept fines if needed. Estonia hopes the new EU Commission composition will prove receptive to a 2-year postponement.
Status of the Palagapeegel ("Pay Mirror") digital reporting portal previously confirmed in development: now in limbo pending political clarity.
No draft transposition law has been published. Reporting was previously expected to apply to approximately 900 organisations (1% of all employers); first reports due in 2027 based on second-half 2026 data — both timelines are now uncertain.
Workers will be able to claim under the directive's direct effect from June 7, 2026 even where Estonian law is not in force.
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Finland
Status: Draft in progress — implementation now expected late 2026 or early 2027 (1 June 2026 update). Finland's original 18 May 2026 entry-into-force target has lapsed. The Ministry of Social Affairs and Health closed its public consultation on 9 February 2026. The final government proposal is now expected mid-June 2026, parliamentary review in autumn 2026, and actual entry into force is now expected in late 2026 or early 2027.
Key provisions in the draft:
• Starting salary or salary range must be disclosed early in the hiring process — not necessarily in job ads, but in due time prior to salary negotiations.
• Employees entitled to written confirmation of their own salary and the average pay of colleagues of the opposite gender performing the same or equivalent work.
• Fines from €5,000 to €80,000 depending on severity, repetition, intent and employer size.
Direct effect applies from 7 June 2026 until the Finnish law enters into force.
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France
Status: Draft bill — France missed the 7 June 2026 deadline. In the night of 4–5 June 2026, the Ministry of Labour transmitted a new version of the transposition bill to social partners — 24 pages, 22 articles, structured around three objectives: strengthen pay-gap correction measures, increase pay transparency, and clarify sanctions. A first draft had been sent to social partners on 6 March 2026; no Conseil des ministres review has yet taken place. Adoption is now openly targeted for autumn/late 2026; national application from 2027.
Direct effect applies from 7 June 2026: employees and job applicants can rely on the directive against their employer for sufficiently precise and unconditional provisions, regardless of whether French law is in force.
Key provisions of the draft bill (subject to parliamentary amendment):
• 7 new pay gap indicators replacing the Index Égalité Professionnelle, including one measuring gaps at equal or equivalent work.
• Salary ranges mandatory in all job postings.
• Salary history ban.
• Burden of proof reversed (on the employer).
• Threshold at 50+ employees.
• Administrative fines up to 1% of payroll (2% for repeat offenders).
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Germany
Minister Prien's commission delivered its final report in November 2025. A Referentenentwurf (draft bill) is expected in early 2026, building on the existing EntgTranspG (2017).
Key specifics: First pay gap reports based on 2026 payroll data, reporting threshold at 100+ employees, extended co-determination rights for works councils (Betriebsrat), sanctions based on company revenue with possible exclusion from public procurement.
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Greece
No draft law or timeline published yet.
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Hungary
No draft law or timeline published yet.
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Ireland
Status: In discussion. In a written answer to a parliamentary question on 26 May 2026, the Minister for Children, Disability and Equality formally confirmed Ireland will miss the 7 June 2026 deadline, citing late EC workshops (September 2025) and late EIGE/EC guidance (March 2026). The Pay Transparency Bill is not on the Government's Summer Legislative Programme priority list (RTÉ, 17 May 2026), and the Heads of Bill for the full transposition (including gender pay gap reporting) are still being drafted.
The Department of Children, Disability and Equality confirmed implementation will happen on a phased basis, starting with pre-employment salary disclosure. Employers will not be penalised for elements absent from Irish law on 7 June 2026.
The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 (partial transposition covering pre-employment pay transparency) completed pre-legislative scrutiny in October 2025; a separate general scheme covering gender pay gap reporting and the remaining provisions has yet to be published.
Direct effect applies from 7 June 2026: individual workers can bring claims against employers regardless of whether Irish law is in place.
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Italy
Status: Law in effect. Italy's legislative decree transposing Directive 2023/970 (Council of Ministers final approval 30 April 2026) entered into force on 7 June 2026. Italy is one of only two EU Member States (with Slovakia) to transpose on time.
Reporting threshold: 100+ employees — the lowest in the EU. Annual reporting for 250+ employees from 2027; triennial for 150–249 from 2027; triennial for 100–149 from 2031.
5% trigger: an unjustified gender pay gap of 5% or more obliges the employer to justify it and initiate a joint evaluation with union representatives and the Labour Inspectorate to adopt corrective measures.
Pay disclosure in recruitment: from 7 June 2026, employers must indicate the initial remuneration or the salary range for the offered position. Salary-history questions are banned.
Worker information rights: two-month response window for average pay by gender and category. Coverage includes all public and private employers and subordinate employment relationships including managers; apprentices, domestic and intermittent workers excluded.
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Latvia
Last update: April 1, 2026 — The Ministry of Welfare published a draft law transposing Directive 2023/970 for public consultation; the consultation window closed April 9, 2026.
Latvia has opted for a 1:1 transposition approach with three notable deviations:
(1) Goes beyond the Directive by requiring employers to include pay details directly in job advertisements (not merely during negotiation).
(2) Narrower definition of "remuneration", limited to amounts paid on a regular basis — potentially excluding bonuses, benefits in kind and allowances from scope.
(3) Low maximum penalty for corporate employers: €14,000, with no enhanced fines for repeat offenders.
Next steps: the bill moves to the Cabinet of Ministers and then to the Saeima. Timely transposition by June 7, 2026 is possible but requires urgent parliamentary status. Existing rule: salary indication in job postings has been mandatory since 2018.
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Lithuania
A partial draft was announced in late 2025 but not formally published.
Salary indication in job postings mandatory since 2022. Internal pay structures mandatory from 20 employees.
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Luxembourg
No public activity reported. No draft law published.
Internal pay report to employee representatives every two years from 50 employees.
Voluntary tool ("Logib-Lux") available to analyse pay gaps.
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Malta
Partial obligations effective since August 2025.
One of the few EU countries with live enforcement of some directive provisions.
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Netherlands
Status: Bill submitted to Parliament (Tweede Kamer). On 21 May 2026, the Dutch Minister of Social Affairs and Employment formally submitted the bill implementing Directive 2023/970 to the House of Representatives (Tweede Kamer), moving it from the Council of State stage into the ordinary parliamentary process (committee scrutiny, debate, vote, then Senate). The Netherlands will miss the 7 June 2026 deadline; target effective date is 1 January 2027.
If the 1 January 2027 EIF is met, the first gender pay gap report for 150+ employers would be due 7 June 2028 (covering 2027); employers with 100–149 employees would follow by 7 June 2031.
Council of State opinion (7 April 2026): the bill's proposed postponement of the first reporting requirement for 150+ employers to 7 June 2028 was found not permitted under the directive; the reporting deadline is expected to be realigned with the directive's text.
Key provisions: 1:1 transposition approach, reporting every 3 years for 150+ and annually for 250+, joint pay assessment triggered at 5%+ unjustified gap with a 6-month rectification window, works council involvement for corrective measures. Direct effect applies from 7 June 2026 despite the national delay.
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Poland
Status: Draft legislation published. Phase 1 (pre-employment pay transparency) has been in force since 24 December 2025 under an earlier amendment to the Labour Code. On 4 May 2026 the government released the second draft of the Act implementing Directive 2023/970, dated 29 April 2026, accompanied by a draft regulation specifying the detailed indicators, calculation methods and formulas for the gender pay gap report.
Reporting threshold: 100+ employees (more demanding than the Directive's 150+). Annual reporting for 250+; triennial for 100–249.
Formula: annual gender pay gap = (average pay of women − average pay of men) / average pay of men × 100%. Required indicators include overall pay gap, supplementary/variable components gap, median gap, percentage of women and men in each pay quartile, and category-level pay gaps.
Pay-info response window: 30 days for most employers (14 days for companies with fewer than 50 employees) — far stricter than the Directive's 2 months.
A centralised government job evaluation tool will be made available to employers. Realistic adoption window: Q3 2026.
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Portugal
No draft law published yet.
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Romania
Last update: April 10, 2026 — On March 30, 2026, Romania's Ministry of Labour, Family, Youth and Social Solidarity published a revised draft law transposing Directive 2023/970 for public consultation; the consultation window closed April 8, 2026.
Romania is now a serious contender to meet the June 7, 2026 deadline.
Key provisions: 30-working-day response window to pay information requests (stricter than the Directive's 2 months), extendable by another 30 working days. 90-working-day remediation window, extendable to 6 months where justified. Workers can formally request pay information via the National Council for Combating Discrimination (CNCD/ANES) — a state enforcement channel beyond the Directive's minimum.
Reporting thresholds: 250+ employees annually from June 2027; 150–249 every 3 years from June 2027; 100–149 triennial from June 2031. Joint pay assessments triggered at 5%+ unjustified gap, with consultation (not just cooperation) with worker representatives required during remediation.
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Slovakia
Status: Law in effect. Slovakia's Equal Pay Act (Act No. 76/2026 Coll., published 8 May 2026) entered into force on 7 June 2026 as scheduled. Slovakia was the first EU Member State to complete transposition (National Council adoption 15 April 2026) and is now live alongside Italy.
Goes beyond the Directive: equal-pay protections extend beyond male/female comparisons — same-sex employees performing equal work or work of equal value can also bring pay claims.
Reporting thresholds: first reports due 7 June 2027 for employers with 150+ employees. Annual reporting for 250+; triennial for 150–249.
Enforcement: the Labour Inspectorate can issue fines of up to €100,000.
Pre-employment: salary range disclosure obligations and salary-history ban aligned with directive minimums.
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Slovenia
Last update: April 2026 — The Slovenian government has formed an inter-ministerial working group preparing draft legal solutions to transpose Directive 2023/970. The responsible ministry states it expects to meet the June 7, 2026 deadline.
No public draft text has been released yet.
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Spain
UPDATE — May 8, 2026: Spain's public consultation on the draft Royal Decree transposing Directive 2023/970 has now closed after a 14-day window (April 24 → May 8). The Ministry of Labour (MITES) moves to the drafting phase.
Realistic timeline: drafting + social-partner alignment + State Council review + Council of Ministers approval cannot realistically be compressed into the 30 days remaining before the June 7, 2026 deadline. Spain will miss the deadline by an estimated 4–8 weeks.
Building on existing infrastructure: Spain already has the most developed equal-pay legal framework in the EU pre-directive — Registro Retributivo (mandatory pay registry for all companies) and Auditoría Retributiva (mandatory pay audits for 50+ employees). The Royal Decree adds directive-specific obligations layered on top.
Expected provisions: pay-setting policies and structures must be transparent; salary range disclosure to candidates; salary history ban; gender pay gap reporting aligned with EU thresholds (250+ first, then 150+ phased); worker information request mechanism; stricter non-compliance consequences.
Procedure note: Spain is transposing via a Royal Decree, not new primary legislation — a faster procedure but with narrower scope than parliamentary law would allow.
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Sweden
Update — 22 May 2026: The European Commission formally confirmed that the Pay Transparency Directive will not be postponed or renegotiated, directly rejecting the Swedish government's request. With no domestic transposition bill, Sweden missed the 7 June 2026 deadline and is now exposed to infringement proceedings under Article 258 TFEU. Public-sector employers are nonetheless bound by direct effect from 7 June 2026.
On March 26, 2026, Sweden announced it will not submit the pay transparency directive proposition to the Riksdag and will instead push at EU level for a postponement of the deadline and a full renegotiation of the directive. Minister Nina Larsson stated the directive is "far too administratively burdensome" and risks "undermining its own gender equality goals."
Sweden originally voted against the directive in 2023. The government's position is that the directive's job evaluation and "equal value" work assessment requirements are incompatible with Sweden's collective bargaining model. Existing obligations under the Discrimination Act (lönekartläggning for employers with 10+ employees) remain in force.
Previously, Sweden had proposed implementation by January 1, 2027, with first salary reports to the Discrimination Ombudsman (DO) due by May 20, 2028. These timelines are now suspended pending the outcome of EU-level negotiations.
Key provisions from the suspended draft: obligations for 10+ employees for national pay analyses; EU-aligned reports for 100+ employers; fines SEK 150,000–500,000.
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Frequently asked questions
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What is the EU Pay Transparency Directive and when does it take effect?
The EU Pay Transparency Directive is a regulation aimed at closing the gender pay gap across member states.
It requires companies to disclose salary ranges, ensure equal pay for equal work, and report pay gap data.
It will come into force in 2026, but companies should start preparing now.
Which companies are affected by the Pay Transparency Directive?
The directive applies to companies with 100 or more employees, with phased reporting obligations based on company size.
Organizations will need to provide pay transparency both at the recruitment stage and in internal compensation structures.
How can Figures help your company comply with the Pay Transparency Directive?
Figures is a leading compensation benchmarking and pay transparency platform tailored for European companies. It helps you:
- Benchmark salaries using real-time, localized data
- Ensure pay equity with gender gap analysis tools
- Establish internal fairness with clear job leveling frameworks
- Generate compliance-ready reports aligned with EU requirements
- Communicate salaries transparently to employees and candidates
Is Figures suitable for companies of all sizes?
Yes. Whether you're scaling your team or running an established organization, Figures supports HR teams, CFOs, and CEOs with data-driven compensation insights that grow with you.
When should companies start preparing for the directive?
Now. Although enforcement starts in 2026, organizations that begin early will have time to identify pay gaps, update their salary structures, and avoid last-minute compliance stress.
Can Figures help with salary ranges in job ads, as required by the directive?
Absolutely. Figures helps define data-backed salary bands for roles, making it easy to include transparent pay ranges in job ads—an essential step toward compliance.
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