Pay transparency: stay one step ahead

A ministerial draft has been sitting in government coordination since June 2026 and no law exists. It would require income reports from 100 employees, pay ranges in job ads and an individual right to pay information, with a one-year grace period before penalties.

Two regional public-sector decrees are in force — Wallonia-Brussels since September 2024, Flanders since 7 June 2026 — but the federal private-sector bill is still unpublished. Belgium was the first Member State to formally ask the Commission for a six-month extension.

The draft transposition bill (Anti-Discrimination Act amendment) was formally tabled in the National Assembly in September 2026 and is now in review across four parliamentary committees, incorporating 25 amendments from the spring consultation.

The Ministry of Labour presented a free, EBRD-backed job-evaluation methodology on 9 September 2026 and announced a National Pay Transparency System for gap reporting, but the Labour Act amendments are still unpublished and untabled. Adoption is expected in autumn 2026.

A comprehensive draft published on 26 January 2026 goes well beyond the Directive: a broad definition of pay, weighted gender-neutral job evaluation, and criminal liability with possible personal liability for company officers. No parliamentary timetable is confirmed.

The bill was filed in the Chamber of Deputies on 8 September 2026 as parliamentary print 300 after government approval on 31 August. Every employer, with no size exemption, will have to build a written pay system grading jobs by value, the broadest structural obligation of any Member State. First reading not yet scheduled; entry into force targeted 1 January 2027.

A draft amending the Equal Pay Act was consulted from 26 February 2026, proposing entry into force on 1 January 2027. The March 2026 general election left no majority, and the new parliament will have to restart the process.

A partial transposition law entered into force on 13 July 2026, covering recruitment pay information, the salary-history ban and the right to discuss pay. Mandatory gender pay gap reporting is deliberately deferred to 2028.

Bill HE 129/2026 had its referral debate on 15 September 2026 and is now with the Employment and Equality Committee, with entry into force still targeted for 1 January 2027. Reporting starts at 100 employees and runs through the existing Incomes Register.

The bill was deposited at the Senate on 10 September 2026 as PJL n. 944, referred to the Commission des affaires sociales under the accelerated procedure. No committee or floor date yet. Text: 50+ threshold, seven indicators replacing the Index from 2028, fines up to 1% of payroll.

Germany missed the deadline with no draft bill published. The government now targets early 2027, building on the expert commission's bureaucracy-lean recommendations and the existing 2017 pay transparency act.

Law 5316/2026 was voted on 2 July 2026 and published on 6 July — the fifth Member State to complete transposition. Most operational obligations apply from 1 November 2026, and employers with 150+ face a first reference period ending 31 December 2026.

The transposition law is in the government's autumn 2026 legislative programme, targeting adoption in October 2026 and entry into force from 2027, but no draft text has been published and nothing has been tabled in Parliament.

The Minister confirmed on 26 May 2026 that Ireland would miss the deadline, and the Pay Transparency Bill is not on the priority legislative programme. Implementation will be phased, starting with pre-employment pay disclosure, and employers will not be penalised in the meantime.

Legislative Decree 96/2026 entered into force on 7 June 2026, making Italy one of only four Member States to transpose on time. The reporting threshold is 100 employees — the lowest in the EU.

The draft is at adoption stage before the Cabinet and the Saeima, with no confirmed date. It goes beyond the Directive by requiring pay in job ads, but narrows the definition of remuneration and caps corporate fines at EUR 14,000.

Labour Code amendments took effect on 7 June 2026 and implementing regulations followed on 31 July. Sodra computes the pay gap indicators directly from payroll data, so employers do not self-report — their remaining exposure is pay-system alignment by 31 December 2026.

No public activity and no draft law. A biennial internal pay report to employee representatives applies from 50 employees, and the voluntary Logib-Lux tool is available to analyse gaps.

Legal Notice 173 of 2026 completed full transposition on 5 June 2026, two days ahead of the deadline, building on the pre-employment measures introduced in August 2025. Malta is one of only four Member States to transpose on time.

The Tweede Kamer plenary debate on bill 36949 has slipped to week 2 of 2027, so the 1 January 2027 target the government reaffirmed on 2 September is no longer achievable; a Tweede Kamer vote and Eerste Kamer passage still remain.

Recruitment transparency has been in force since 24 December 2025, but the full implementation act is still in inter-departmental coordination and entry into force now slips to Q1 2027. The pay-information response window is 30 days — far stricter than the Directive's two months.

Public appraisal of bill PL 5573 closed on 25 August 2026 and the text goes to Parliament with an urgency request, with no date set. Repeat breaches can cost tax incentives, public benefits and access to public tenders for up to two years.

Bill L445/2026 is in Senate committees under emergency procedure. On 21 September 2026 the Senate extended its examination period to 60 days, making 17 October 2026 the tacit adoption date before the bill moves to the Chamber of Deputies.

The Equal Pay Act entered into force on 7 June 2026 and Slovakia was the first Member State to transpose. The first hard deadline in the EU has already passed: employers had until 31 July 2026 to have a compliant, job-evaluated pay structure in place.

An inter-ministerial working group was formed in early 2026 but no draft text has been released and no adoption timetable announced. Slovenia sits among the Member States with neither a published draft nor a declared political position.

Consultation on the draft Royal Decree closed on 24 August 2026, and the text either reaches the Council of Ministers in September or slips into 2027 under union pressure. It is a deliberate partial transposition: recruitment pay disclosure is absent and left to a later instrument.

Sweden announced in March 2026 that it would not submit the bill to the Riksdag, seeking a postponement and a full renegotiation; the Commission formally refused on 22 May. Preparatory work has been handed to the Equality Ombudsman, who reports by 1 November 2027 — pointing to no legislation before 2028.