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
Last update: April 2026 — A Ministry of Labour and Social Policy (MLSP) working group has prepared a draft amendment to the Anti-Discrimination Act (Zakon za zashtita ot diskriminatsia) and the Labour Code transposing Directive 2023/970. The government decision targets adoption by the National Assembly by May 29, 2026.
No public draft text has been released yet, making the May 29 target ambitious.
Key proposed trigger: an unjustified gender pay gap of 5% or more within a category of workers persisting for 6 months will require a mandatory joint pay assessment in collaboration with worker representatives.
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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
Draft bill submitted to Parliament in late 2025. Entry into force targeted for May 18, 2026.
"Pure implementation" approach, closely aligned with directive minimum requirements. Reporting threshold: 100+ employees.
Noncompliance fines confirmed at €5,000–€80,000 (among the highest in the EU).
Pay audits already mandatory every two years for companies with 30+ employees.
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France
Last update: March 19, 2026 — Final social partner consultation meeting held March 19. Draft bill (9 articles, private sector) first transmitted March 6. CCFP consultation planned for April-May 2026. Parliament deposit targeted end of May.
Key provisions: 7 new pay equality indicators replacing the current Index égalité. Salary ranges mandatory in job postings. Salary history ban. Employee right to information on average pay by gender. Reporting: companies 100–249 employees every 3 years (150+ from 2027, 100–149 from 2031). Threshold maintained at 50+ employees. Joint pay assessment triggered at 5%+ unjustified gap. Burden of proof reversed. Administrative fines proportional to payroll + exclusion from public procurement.
France will miss the June 7, 2026 deadline. Adoption targeted for September 2026 at the latest.
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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
Last update: April 22, 2026 — Mason Hayes & Curran (MHC) published a survey of 500 Irish employers showing only 31% expect a positive effect from the directive, and more than 1 in 5 call it an "unnecessary burden." The Department of Children, Disability and Equality has confirmed Ireland will miss the June 7, 2026 deadline and will introduce a phased rollout starting with pre-employment obligations (salary disclosure in job advertisements). Heads of Bill are still being drafted.
Two-bill strategy: (1) Equality and Family Leaves (Miscellaneous Provisions) Bill 2024 — already covers the salary history ban (Article 5 of the directive); (2) standalone Pay Transparency Bill — General Scheme not yet published. Pay secrecy clauses prohibited. Reporting threshold expected at 50+ employees. Joint pay assessment where unjustified gap exceeds 5%.
The Irish Congress of Trade Unions (ICTU) has warned that workers with valid claims will be able to seek compensation backdated to June 7, 2026 under the directive's direct effect — creating real liability for Irish employers from that date regardless of the missed deadline.
Precedent: Ireland was fined €1.54M by the CJEU in August 2025 for missing the Work-life Balance Directive deadline.
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Italy
On February 5, 2026, Italy's Council of Ministers approved a draft Legislative Decree implementing Directive (EU) 2023/970 on pay transparency. The Senate's Labor Commission delivered a favorable opinion with observations on March 11, 2026. The decree now moves to the Chamber of Deputies before returning to the Council of Ministers for final adoption.
Italy remains on track to meet the June 7, 2026 transposition deadline and is expected to be one of the first major EU economies to complete transposition.
Key provisions: salary ranges mandatory in job advertisements, salary history ban, reporting threshold at 100+ employees, joint pay assessment triggered at 5%+ unjustified gender pay gap. Classification of 'equal work' and 'work of equal value' anchored to national collective bargaining agreements (NCBAs). Individual pay components excluded from pay level definition.
Companies with 50+ employees must make pay criteria and levels accessible to all employees. Employers must respond to employee pay information requests within two months. Burden of proof reversed in pay discrimination cases.
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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
The Netherlands has delayed implementation to January 1, 2027 (later than the June 7, 2026 EU deadline). The European Commission formally rejected this delay on December 18, 2025 and has warned of infringement proceedings under Article 258 TFEU.
Amended draft bill submitted to the Council of State (Raad van State) on January 20, 2026 for advisory opinion. Update March 2026: The explanatory memorandum clarifies that employers with 150+ employees will submit their first pay gap report by June 7, 2028, covering calendar year 2027 data — one full cycle behind the directive's own June 7, 2027 first-report deadline.
Key specifics: 1:1 transposition approach (minimal gold-plating), reporting for 150+ employees every 3 years and 250+ annually, joint pay assessment triggered at 5%+ unjustified gap with 6-month rectification window. Works council involvement required for corrective measures. Direct effect of the directive may apply from June 7, 2026 despite the national implementation delay.
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Poland
One of the most advanced implementations in the EU. Phase 1 live since December 24, 2025 (recruitment transparency rules in force). Full draft published December 16, 2025, targeting June 7, 2026 for full entry into force.
Key specifics: Annual March 31 notification to employees of their rights, 30-day response time for information requests (vs 2 months in directive), fines PLN 2,000–60,000. Draft job evaluation tool published alongside the legislation.
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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
UPDATE — April 15, 2026: Slovakia's National Council adopted the Equal Pay Act, becoming the first EU Member State to fully transpose Directive 2023/970. The law enters into force on June 7, 2026 — the exact EU deadline.
Key provisions:
(1) Goes beyond the Directive: equal pay protections extended beyond gender — same-sex employees performing equal work or work of equal value can now bring pay claims. Slovakia is the first Member State to broaden the comparator class.
(2) Reporting: first reports due June 7, 2027 for employers with 150+ employees. Annual for 250+; triennial for 150–249.
(3) Enforcement: Labour Inspectorate empowered to issue fines up to €100,000.
(4) Pre-employment salary range disclosure 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
Working group active in H2 2025. Spain benefits from strong existing equality legislation (equality plans and pay audits already required). Targeted updates needed for recruitment transparency requirements under the directive.
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Sweden
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
Got more questions? If we missed anything, just reach out and we’ll fill you in on all the details.
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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