No public legislative activity reported. Only minor adjustments expected given Austria's existing equal pay framework in place since 2011.

Status: partial (regional public sector only) — deadline missed. In early June 2026, Belgium's Minister for Employment and Minister for Equal Opportunities co-signed a letter to the European Commission formally requesting a six-month extension — the first Member State to do so. The request is unlikely to succeed: the Commission has rejected all postponement requests to date.

In force: the Wallonia-Brussels Federation decree (French-speaking public sector, since September 2024) and the Flemish public-sector decree (since 7 June 2026).

Federal private-sector draft: still unpublished. Realistic transposition horizon is now H1 2027. Belgian private-sector workers can rely on the directive's direct effect since 7 June 2026.

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.

No public activity or draft law reported.

No specific pay transparency laws currently in force.

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.

UPDATE - July 15, 2026: the draft has cleared comment resolution and is filed for government. The Ministry of Labour and Social Affairs (MPSV) completed the inter-ministerial comment procedure on the Labour Code amendment transposing Directive 2023/970. The material is registered under ref. OVA 559/26, last amended 15 July 2026, status filed pending government consideration. No Chamber of Deputies bill number exists yet, so the parliamentary stage has not begun. Entry into force is proposed for 1 January 2027, with selected provisions at 1 January 2028 and some as late as 1 January 2031.

Harder than the minimalist label suggests. The published text contains the broadest structural obligation of any Member State:

New section 109a - every employer must create a written pay system, describing pay form, components and gradation, and including a division of jobs into groups graded by job value (complexity, responsibility, demand). There is no size exemption: a two-person company is in scope. The system is set by collective agreement or by internal regulation.
An equivalent obligation applies to benefits (section 306a): objective, non-discriminatory criteria for any non-wage monetary benefits.

Penalties: up to CZK 1,000,000 for failing to create the pay system - the same band as failing to ensure equal treatment or discriminating. Up to CZK 400,000 for the benefits system. Up to CZK 200,000 each for breaching employee information duties and for asking a candidate about current or previous pay.

Recruitment: the employer must demonstrably inform the candidate of the minimum pay and other monetary entitlements before the employment contract is signed - not a range, and not in the job advertisement. The Ombudsman's push to mandate pay in job ads did not make the text.

Employee information right: written request for own pay and sex-disaggregated average pay within the job group; two-month response; limited to once per calendar year (a concession from the comment procedure). The employer must remind all employees of this right at least annually.

Reporting: 250+ employees annually; 150-249 at a longer interval; employers under 150 may voluntarily request a report from the Ministry by 10 March. Obligations start in 2028 for 150+, 2031 for 100-149.

Unique feature: the Czech Ombudsman acts as a privacy intermediary where sharing pay data could reveal individual compensation - a mechanism no other Member State has proposed.

The Czech Republic missed the 7 June 2026 deadline. Pay-secrecy clauses have been banned since 1 June 2025 via an earlier Labour Code amendment.

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.

UPDATE - July 13, 2026: a partial transposition law is in force. Estonia's amendment law partially transposing Directive 2023/970 was approved by the President on 29 June 2026, published in the State Gazette (Riigi Teataja) on 3 July 2026, and entered into force on 13 July 2026. The amendments strengthen the equal-pay-for-equal-work principle in the Employment Contracts Act and implement core transparency provisions.

What is deferred: mandatory gender pay gap reporting is postponed to 2028. The government continues to push at EU level for amendments reducing the administrative burden on employers. Estonia has legislated the core provisions and postponed the reporting machinery - a partial transposition comparable to Belgium, Ireland and Poland rather than a full one.

Context: in April 2026 Economic Affairs Minister Erkki Keldo had said Estonia would rather pay European Commission infringement fines than transpose the directive in its current form. The July law supersedes that posture: Estonia is transposing, at minimum cost, while seeking a lighter EU-level regime for reporting.

The status of the Palgapeegel ("Pay Mirror") digital reporting portal remains tied to the deferred reporting obligations.

Direct effect: for provisions not yet transposed, workers can rely on sufficiently precise and unconditional provisions of the Directive against public-sector employers since 7 June 2026.

Status: Bill before Parliament. The Finnish government approved the transposition bill (hallituksen esitys) at its plenary session on 9 July 2026 and submitted it to the Eduskunta. Parliamentary handling begins in the autumn 2026 session, with the laws intended to enter into force at the start of 2027. The bill amends the Act on Equality between Women and Men, the Act on the Equality Ombudsman, the Statistics Finland Act, the Incomes Register Act and the Act on the Enforcement of Fines. Implementation is at the Directive's minimum level, per the government programme; the tripartite working group that prepared the text was not unanimous.

Reporting threshold: 100+ employees - below the Directive's 150+. Gender pay gap data is reported to the Equality Ombudsman via the Incomes Register and Statistics Finland, so employers submit through existing payroll reporting rails rather than a new portal.

Key provisions:

Starting salary or salary range disclosed to the applicant in good time before the job interview.
Right to information on the average pay level of employee groups performing the same or equivalent work.
Joint pay assessment with employee representatives where required; failure to comply triggers a payment.
Limitation period for pay-discrimination compensation claims extended to three years.
Fines from EUR 5,000 to EUR 80,000 depending on severity, repetition, intent and employer size.

Finland's average gender pay gap is around 16%, against an EU average of around 12% - cited by the government as the rationale for acting now. The original 18 May 2026 entry-into-force target lapsed and Finland missed the 7 June 2026 deadline.

Direct effect applies since 7 June 2026 until the Finnish law enters into force.

Status: Draft bill — France missed the 7 June 2026 deadline. The revised transposition bill went to the Conseil d'État in June 2026, but the timeline has slipped again: the bill was not placed on Parliament's July 2026 extraordinary session agenda, and the Labour Ministry's revised scenario is now a Council of Ministers presentation during summer 2026, parliamentary debate at the end of 2026, and adoption before the May 2027 presidential election. French press report no transposition before spring 2027. Target entry into force: 1 January 2028.

Phased compliance by company size (from promulgation): 150+ employees within 1 year, 100–149 within 3 years, 50–99 within 6 years.

Direct effect applies since 7 June 2026 for sufficiently precise and unconditional provisions.

Key provisions of the draft bill (subject to parliamentary amendment):

• 7 new pay gap indicators replacing the Index Égalité Professionnelle from 2027.
• 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).

Status: In discussion — deadline missed. Germany missed the 7 June 2026 transposition deadline with no Referentenentwurf (draft bill) published. A cabinet decision expected for the end of June 2026 did not materialise; as of mid-July 2026 the government's stated target is implementation by early 2027, building on the expert commission's final report (recommending a bureaucracy-lean implementation) and the existing EntgTranspG (2017).

Since 8 June 2026 the directive applies directly to public employers, and German courts must interpret national law in conformity with the directive — key provisions already shape German employment law despite the absent implementation act.

Expected specifics remain: first pay gap reports based on 2026 payroll data, 100+ employee reporting threshold under discussion, extended works council (Betriebsrat) co-determination rights, revenue-based sanctions with possible exclusion from public procurement.

Status: Law adopted. Greece transposed Directive 2023/970 with Law 5316/2026, voted by Parliament on 2 July 2026 and published in the Government Gazette on 6 July 2026 — the fifth EU Member State to complete transposition and the first in southern Europe. The draft moved from public consultation (3–17 June) to adoption in one month.

Most operational obligations apply from 1 November 2026: pay information rights, recruitment transparency (salary range disclosure to candidates, salary history ban), gender pay gap reporting, joint pay assessments, remedies and protection against victimisation. Other provisions apply since 6 July 2026.

Transitional reporting rule: for employers with 150+ employees, the initial reference period runs from entry into force through 31 December 2026 — one of the shortest compliance runways in the EU.

No draft law or timeline published yet.

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.

Status: Law in effect. Italy's transposition of Directive 2023/970 — Legislative Decree No. 96/2026 — was published in the Gazzetta Ufficiale on 1 June 2026 and entered into force on 7 June 2026. Italy is one of only four EU Member States (with Slovakia, Lithuania and Malta) 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.

Status: Draft legislation published — deadline missed. Latvia's draft transposition law (first published 26 March 2026 by the Ministry of Welfare; consultation closed 9 April) is at the adoption stage before the Cabinet of Ministers and the Saeima, with no confirmed implementation timeframe. Latvia missed the 7 June 2026 deadline.

1:1 transposition with three notable deviations:

(1) Goes beyond the Directive by requiring pay details directly in job advertisements (mandatory in Latvia since 2018).

(2) Narrower definition of "remuneration", limited to regularly paid amounts — potentially excluding bonuses, benefits in kind and allowances.

(3) Low maximum penalty for corporate employers: €14,000, with no enhanced fines for repeat offenders.

Direct effect applies since 7 June 2026.

Status: Law in effect. Lithuania transposed Directive 2023/970 through Labour Code amendments enacted by the Seimas as Law No. XV-969 on 21 May 2026. Most provisions took effect on 7 June 2026, making Lithuania one of only four EU Member States (with Slovakia, Italy and Malta) to transpose on time.

UPDATE - July 31, 2026: implementing regulations are in force. The Minister of Social Security and Labour issued implementing regulations on 17 July 2026, effective 31 July 2026, detailing the collection, calculation, submission and publication of pay data through Sodra and the procedure for conducting joint pay assessments. Sodra computes the gender pay gap indicators directly from payroll data - employers do not self-report. The employer's remaining exposure is therefore entirely in pay-system alignment.

In force from 7 June 2026: a ban on asking candidates about pay history, the express right of workers to disclose their own pay, and the right to request pay-level information by gender and category.

Deferred elements: employers have until 31 December 2026 to align internal pay systems, and monthly pay-data submission to the State Social Insurance Fund Board (SoDRA) begins on 1 January 2027. Salary indication in job postings has been mandatory in Lithuania since 2022.

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.

Status: Law in effect. Malta completed full transposition of Directive 2023/970 with Legal Notice 173 of 2026 (Equal Pay (Transparency and Reporting) Regulations, 2026), published in Government Gazette No. 21,661 on 5 June 2026 with immediate effect — ahead of the 7 June deadline. This builds on the foundational pre-employment measures introduced by Legal Notice 112 of 2025 in August 2025.

Malta is one of only four EU Member States (with Slovakia, Italy and Lithuania) to transpose on time. The regulations cover pay transparency in recruitment, worker information rights and gender pay gap reporting obligations.

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.

Status: Draft legislation published — 2026 entry into force now unlikely. Phase 1 (pre-employment pay transparency) has been in force since 24 December 2025. The second draft of the full implementation act (UC127, dated 29 April 2026, published 4 May) remains in inter-departmental coordination and public consultation; it was not published by end of June 2026, the threshold Polish practitioners flagged for entry into force in 2026. Realistic entry into force now slips to Q1 2027.

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%, with overall, variable-components, median, quartile and category-level indicators.

Pay-info response window: 30 days for most employers (14 days for companies under 50 employees) — far stricter than the Directive's 2 months. A centralised government job evaluation tool will be made available to employers.

UPDATE - August 5, 2026: a draft transposition bill is finally out. The Government published a draft bill (PL 5573) transposing Directive 2023/970 on 5 August 2026, expressly framed as a partial transposition. Social partners are analysing the text through August; it must then pass Parliament and receive the President's approval, entering into force on the first day of the month after publication in the Diario da Republica.

Key provisions of the draft:

Employers must make available the criteria used to determine pay, pay levels and pay progression. Companies with fewer than 50 employees are exempt from the progression-criteria disclosure.
Employers with 50+ employees face reporting obligations covering mean and median pay gaps, variable pay, quartile distribution and differences within groups of workers performing the same work or work of equal value.
An unjustified pay gap of at least 5% can trigger a mandatory joint pay assessment with worker representatives if not justified or corrected.
No obligation to state the salary in job advertisements: the draft allows pay information to be communicated only "before signing" the contract - not in the advert and not before the interview. This is a likely non-conformity point against the Directive, which requires disclosure in good time before the interview, and the most contested feature of the text in Portuguese media.

Deadline context: Portugal missed the 7 June 2026 transposition deadline and remains exposed to infringement proceedings under Article 258 TFEU. Direct effect applies since 7 June 2026: workers and candidates can rely on sufficiently precise and unconditional provisions of the Directive against public-sector employers, and national courts must interpret Portuguese law in conformity with the Directive.

What employers should do now: the structural work the draft names - grading jobs by value on objective, gender-neutral criteria, documenting pay levels and progression rules - has a lead time measured in months and does not depend on the final text.

Status: Draft legislation published — revised text before the Senate under emergency procedure. Romania's draft transposition law was registered with the Senate on 17 June 2026 as draft law B392/2026; the emergency procedure was approved on 22 June 2026. On 7 July 2026 the Senate published a revised version of the text. Despite the emergency procedure, adoption is now expected in autumn 2026 — which would still make Romania the sixth Member State to transpose.

What changed in the revised text: fines are re-indexed to the national minimum gross wage (3–5 minimum wages for standard breaches, 5–10 for repeated breaches) and escalate automatically as the minimum wage rises; job applicants must receive itemized information on variable pay components and benefits, not just a global salary range; a 3-year limitation period applies to pay discrimination claims (running from the act, from awareness of it, or from termination); final CNCD discrimination findings can ground civil damages claims in court.

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; workers can formally request pay information via the CNCD/ANES.

Reporting thresholds: 250+ employees annually from June 2027; 150–249 every 3 years from June 2027; 100–149 triennial from June 2031. Reporting covers mean and median pay gap, variable components and quartile distribution. Joint pay assessments triggered at 5%+ unjustified gap.

Direct effect applies since 7 June 2026.

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).

First hard deadline in the EU has passed: 31 July 2026. Employers established before 7 June 2026 had until 31 July 2026 to have a compliant pay structure in place - pay levels determined on objective, gender-neutral job-evaluation criteria that allow an assessment of whether workers perform equal work or work of equal value, and communicated to employees. Employers had roughly seven weeks from entry into force. This was the first concrete, dated operational obligation imposed on private employers anywhere in the EU under the Directive.

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 EUR 100,000.

Pre-employment: salary range disclosure obligations and salary-history ban aligned with directive minimums.

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.

UPDATE - August 3, 2026: the draft Royal Decree is now in public consultation. The Ministry of Labour published the draft Real Decreto transposing Directive 2023/970 for public hearing (audiencia e informacion publica) on 3 August 2026, moving the text out of the closed social dialogue table into formal public procedure. The driver is defensive: Ministry sources concede Brussels could open an infringement procedure with daily fines if the decree is not approved before September. The Royal Decree route bypasses Parliament, reforming Real Decreto 902/2020 on equal pay rather than passing new primary legislation.

Key provisions of the published draft:

All employers must inform employees of the criteria determining pay and the pay levels of each professional category.
Employers with 50+ employees must detail salary progression criteria and explain how an employee moves to a higher pay level.
Workers or their representatives can request individual pay data and sex-disaggregated average pay for equivalent roles in writing; the employer has two months to respond.
Employers with 50+ report mean and median gaps by category, complements and sex distribution to a new Comision para el seguimiento de la transparencia retributiva, which publishes sector-comparable results for at least four years.
Unjustified gaps above 5% must be corrected within two months.
Pay confidentiality clauses in contracts and collective agreements are void.

Still contested. CCOO and UGT have rejected the current draft. CCOO wants the 50-employee threshold lowered and equal value assessed on annual rather than hourly pay. Both want statutory-rank changes (Estatuto de los Trabajadores, LISOS, reversed burden of proof, exclusion from public tenders above a 5% unjustified gap), which would force conversion into a parliamentary bill and push approval past September.

Building on existing infrastructure: Spain already has the most developed pre-directive equal pay framework in the EU - Registro Retributivo and Auditoria Retributiva for 50+ employees. What the decree adds is pay progression criteria and category pay levels: job architecture, not reporting.

Spain missed the 7 June 2026 deadline; the Directive has direct effect on public-sector employers since 8 June 2026.

Update - June 2026: the government has tasked the Equality Ombudsman with preparing implementation. In June 2026 the government issued a formal assignment (regeringsuppdrag) instructing the Discrimination Ombudsman (DO) to continue preparatory measures for implementing Directive 2023/970, through promotion work on employers' pay-mapping (lonekartlaggning) practice. The stated purpose is to build knowledge of how pay mapping is done in practice and what support employers need, as a basis for implementing the directive. DO must report to the Ministry of Employment by 1 November 2027.

This does not reverse Sweden's political position, but it does mean preparatory work is formally under way. Read together, the signals point to no Swedish legislation before 2028.

Position unchanged: on 26 March 2026 Sweden announced it would not submit the transposition proposition to the Riksdag, pushing instead at EU level for a postponement and a full renegotiation of the directive. On 22 May 2026 the European Commission formally confirmed the directive will not be postponed or renegotiated, rejecting the Swedish request. Sweden missed the 7 June 2026 deadline and is exposed to infringement proceedings under Article 258 TFEU. Public-sector employers are bound by direct effect from 7 June 2026.

Sweden voted against the directive in 2023. The government's position is that the job evaluation and equal-value assessment requirements are incompatible with Sweden's collective bargaining model. Existing obligations under the Discrimination Act (lonekartlaggning for employers with 10+ employees) remain in force.

Key provisions from the suspended draft: obligations from 10+ employees for national pay analyses; EU-aligned reports for 100+ employers; fines of SEK 150,000-500,000. Implementation had been proposed for 1 January 2027, with first reports to DO due by 20 May 2028 - both timelines are suspended.