EU Pay Transparency Directive Legal Tracker

Status: Partially in force — pay transparency applies in four federal states, to their own public services only.

There is no federal instrument, so no private-sector employer is covered, and Austria has missed the transposition deadline.

The four states are not one regime. Upper Austria is the most demanding and is already retrospective: its public employers have been under the full set of duties since 7 June 2026, with a two-month reply period to a pay request and a seven-metric report from 7 June 2027 covering calendar 2026.

Lower Austria has had exactly two duties since 4 June 2026: state the monthly minimum pay for the post in the advertisement, and stop asking candidates what they earn. There is no information right and no reporting duty.

Burgenland has applied since 1 October 2026 and Styria since 22 July 2026, each on its own reporting calendar.

No Austrian instrument attaches a fine to these duties, so the exposure is a claim by a worker or candidate rather than a regulatory penalty.

Status: Partially in force — two public-sector regimes, one in each Community, and a further Flemish instrument in force since 1 October 2026. No federal instrument, so no private-sector duty anywhere in Belgium.

The French Community regime has been in force since 1 January 2025: pay information from the moment a vacancy is published, a pay-history ban covering current and previous employment, gender-neutral notices and job titles, and pay criteria accessible to all staff.

The Flemish Community regime has been in force since 7 June 2026 and takes the Directive's reporting calendar — 7 June 2027 for employers of 150 or more, 7 June 2031 for 100 to 149 — with a two-month reply period and a joint pay evaluation where an unjustified 5% gap is not corrected within six months.

Since 1 October 2026 the rules fixed for each Flemish Community public-sector selection — which already set out the qualifying diplomas, the tests and the assessment criteria — must also state the level, rank and grade of the post and the salary scale attached to it.

Penalties in both Flemish decrees are suspended pending a reform of the Criminal Code that has no commencement date, and the French Community decree creates no fine for its transparency duties.

Status: Bill before parliament.

The bill is a complete regime: all seven reporting metrics, a two-month reply period, and a joint pay assessment triggered by a 5% unjustified gap left uncorrected for six months.

A request to clarify information already given must be answered within fourteen days, and an unjustified difference must be corrected within one year.

The reporting calendar matches the Directive — 7 June 2027 for employers of 150 or more, 7 June 2031 for 100 to 149 — and information that would identify a worker is routed to the union or the equality body rather than refused.Two gaps: the recruitment disclosure duty states no time by which the information must be given, and the bill creates no penalty of its own.

Status: No published text. Croatia has missed the transposition deadline.

The ministry stated on 13 October 2026 that it is preparing amendments to the Labour Act to align with the Directive, and that these would create a national pay transparency system. No draft text has been published and nothing is before parliament.

No substantive provision can be stated: no operative text has been located or read.

A free government job-evaluation methodology was published on 9 September 2026, with separate models for small, medium and large employers. Its use is expressly voluntary and it is not law.

Croatian employers have no national pay transparency obligation today.

Status: Bill finalised after consultation, still not lodged in the House.

A revised post-consultation text exists and is formatted for gazette publication, but it has not been enacted or tabled.

The parliamentary index of bills lodged in 2026 has advanced to the plenary sitting of 22 October 2026. The pay transparency bill has not been lodged at any sitting of this session.

The Minister of Labour said on 6 September 2026 that the bill would go to the Council of Ministers within September. Seven weeks later it has still not been lodged.

No substantive provision can be stated: the operative text has not been read.

Cyprus is in default and what exists is a bill that has not been published. An original and a revised text both sit on the consultation portal and they differ, so any figure circulating for Cyprus should be treated as version-dependent until the final text appears.

Status: Bill before parliament — the first reading was completed on 20 October 2026 and the bill is in committee with a 30-day deadline.

Four duties would start on 1 January 2027: recruitment disclosure, the pay-history ban, the duty to operate a pay system, and the pay-secrecy prohibition.

The information right, the reporting chain and the joint pay assessment are deferred to 1 January 2028, and the 100-employee band to 2031. First report in 2028 for the year 2027.

Fines run to 1,000,000 koruna for failing to operate a pay system, to run a joint pay assessment or to file the report.

Motions to reject the bill at first reading did not succeed, so the 1 January 2027 commencement on the face of the bill remains possible.

Status: Bill before the Folketing — introduced on 8 October 2026, first reading completed on 22 October and the bill now in committee, with commencement set for 1 March 2027.

The reporting duty starts at 50 employees, not 100.

First reports fall due 1 September 2028 for employers of 250 or more and of 150 to 249, and 1 September 2031 for the smaller bands.

The report is filed with a new national equal-pay institute within one month, and the institute publishes six of the seven measures a month later in a form built for comparison between employers.

A pay information request must be answered in writing within two months, and the duty to make pay and pay-progression criteria accessible reaches every Danish employer with no small-employer exemption.

On 26 October 2026 an implementation agreement concluded by the national social partners was laid before the parliamentary committee, and the committee's draft timetable followed on 27 October. The contents of both are not yet established.

Status: Partially in force since 13 July 2026 — recruitment duties only.

Pay or a pay range must be given in a form that can be reproduced in writing, in the advertisement or otherwise, before the job interview, together with any applicable collective-agreement pay terms.

Candidates may not be asked about pay in current or previous employment.

Employers may not obstruct an employee from disclosing their own pay, but a pay-secrecy clause is not made void.

There is no reporting duty, no individual information right, no joint pay assessment and no gender-neutral job title rule. In their place Estonia offers a voluntary State service that calculates an employer's own gender pay gap indicators on request, with no threshold, no frequency and no submission to any authority.

Only the recruitment disclosure duty is supervised by the labour inspectorate. The pay-history ban, the duty not to obstruct disclosure and the equal-pay duty itself sit outside state supervision.

Status: Bill before parliament — the committee reported on 22 October 2026 and recommended adoption essentially unchanged, and the bill now awaits its decisive reading.

The reporting threshold is 100 employees, and the bill leaves its own commencement date blank.

Published guidance from the tax authority puts the employer's own filing at 2 May 2028 for 2027 data, and at 2 May 2031 for 2030 data for the 100 to 149 band, moving to 30 April in later years.

The same guidance begins itemised earnings reporting for pay periods starting on or after 1 January 2027 for employers of 150 or more.

A penalty of €5,000 to €80,000 applies to a late joint pay assessment, from which the public sector is exempt. Gender-neutral job titles are not transposed.

Status: Bill deposited in the Sénat on 10 September 2026, under the accelerated procedure.

The penalties are in the statute: up to 1% of total payroll, and up to 2% for a repeat within five years, imposed administratively.

Indicators must be declared from 50 employees. A job advertisement may not be published without a pay range, and questions about a candidate's current or past pay are prohibited.

There is no fixed start date. The regime commences on a decree to be made at the latest one year after promulgation, with the per-category indicator deferred up to three years for employers of 100 to 149 and up to six years for 50 to 99.

Where the information requested would identify a colleague, the bill refuses it rather than routing it to a representative or the equality body. Most other figures are left to implementing decree.

Status: No published text. The 2017 Pay Transparency Act still governs.

No ministerial draft has been published and the indicated August 2026 cabinet slot passed without one.

Transposition is intended as an amendment to the existing 2017 Act rather than a new statute.

The 2017 regime sits below the Directive on three counts: the individual information right applies only above 200 employees, the reply period is three months, and the employer may refuse where the comparator group is identifiable.There is no pre-employment pay disclosure duty in German law today.

Germany is in default and has no national text to design against, three months after the deadline. A German implementation project should be built directly on the Directive.

The practical warning is the opposite of the usual one: do not treat the German standard as sufficient for group-wide design. Three of its core provisions sit below the Directive and will have to rise.

Status: In force since 6 July 2026 — but the substantive obligations start on 1 November 2026.

An employer told that Greece has been in force since July will under-plan for the 1 November start and for a first report in June 2027 over a part-year reference period.

All seven reporting metrics are reproduced and the Directive's calendar is met exactly: 7 June 2027 for employers of 250 or more and of 150 to 249, 7 June 2031 for 100 to 149.

Two-month reply period; compensation expressly uncapped; pay-secrecy terms prohibited in contracts, collective agreements and work rules. Agency workers count in the user undertaking's report.

A breach carries a fine of €300 to €50,000 for each infringement, imposed by the labour inspectorate, which can also close a department or a whole site on repeat serious findings. The ministerial decision placing a given breach within that band has still not been issued.

Status: No published text and nothing announced. Hungary has missed the transposition deadline.

• No transposing instrument has been published, nothing appears in the official gazette and nothing is before parliament.

• No responsible draft or timetable has been announced.

• Hungarian employers have no national pay transparency obligation today.

Status: No published text. Ireland has missed the transposition deadline, and the transposing bill has no priority drafting status.

No transposing instrument and no general scheme has been published, and there is no bill text.

The Autumn 2026 legislative programme, published on 16 September 2026, lists a Pay Transparency Bill whose heads remain in preparation.

A separate Government bill passed First Stage on 7 October 2026 and completed its remaining stages in both Houses by 20 October. It would change how existing Irish gender pay gap reports are filed, names no directive and is not a transposition of this one, and it is not yet signed.

Existing Irish gender pay gap reporting continues to apply and is not a transposition of this Directive.

Status: In force since 7 June 2026 — the deadline was met, but no fine in Italian law attaches to the transparency duties themselves.

Pay ranges must be given in job advertisements, and the pay-history ban extends to information obtained indirectly through recruiters.

Both same work and work of equal value are anchored to the classification levels of the applicable national collective agreement, which carries a statutory presumption of conformity.

First report 7 June 2027 for employers of 250 or more and of 150 to 249, in addition to the pre-existing biennial gender report, which binds every employer of more than fifty.

The decree's penalty is engaged only where discrimination is established. The exposure for a transparency failure is the reversed burden of proof, compensation with no statutory cap, and up to two years' exclusion from public tenders.

Status: Draft standalone act, not yet before the Cabinet.

The draft is a complete standalone transposition text: twenty-five sections and transitional provisions covering the whole Directive.

The reporting calendar is the Directive's own — 7 June 2027 for employers of 250 or more and of 150 to 249, 7 June 2031 for the 100 to 149 band.

Pay must be stated in the job advertisement itself, which is stricter than the Directive's requirement that it be given before the interview.

Pay-secrecy terms would be void across collective agreements, employment contracts, work rules and employer orders alike.

Enforcement is unusually sharp for a draft: the burden of proof reverses in the labour inspectorate's own proceedings as well as in court, and an unjustified gap above 5% would be a ground for exclusion from public procurement.

A Latvian entity can sensibly plan against this text now, even though it is pre-Cabinet, because the reporting dates are the Directive's own and are unlikely to move with the bill.

Three things drive the work. Recruitment templates change first, because pay goes in the advertisement. Any confidentiality wording covering pay should be removed rather than narrowed. And the enforcement design means a Latvian entity should expect the inspectorate, not only a claimant, to test its documentation.

The rules on how employers will actually file are to come in Cabinet regulations due by 1 May 2027; they do not yet exist.

Status: In force since 7 June 2026 — but the reporting architecture and the information right start on 1 January 2027, and one deadline falls on 31 December 2026.

Every employer, of any size, must have its pay system approved, or reviewed and where necessary amended, by 31 December 2026, with posts grouped on objective gender-neutral criteria and staff information and consultation completed first. The duty is backed by a fine.

The grouping criteria are five — skills, qualifications, effort, responsibility and working conditions — and the pay system must fix a minimum and a maximum for each group.

Employers do not calculate a gap. They file a monthly per-employee payroll dataset from 28 February 2027 and the social insurance authority computes the metrics; the first report is 1 March 2028 for employers of 150 or more and 1 March 2031 for 100 to 149.

The reply period to a pay information request is one month, not two. Public procurement is not addressed.

Status: No bill deposited. Luxembourg has missed the transposition deadline.

• No transposition bill has been deposited in the Chamber of Deputies.

• At a parliamentary committee exchange on 24 June 2026 the minister said consultation with the social partners would continue before a bill is presented.

• The position was re-confirmed on 8 September 2026.

• Luxembourg employers have no national pay transparency obligation today.
  

Status: In force since 5 June 2026 — the deadline was met, and the first reference year is already running.

A pay information request must be answered in writing within eight days, against a two-month floor in the Directive.The first report falls due 7 June 2027 and covers 1 January to 31 December 2026, so the reference year is under way now.

On the numbers Malta is among the closest transpositions in the EU: the seven metrics, the reporting calendar, the 5% and six-month trigger, the three-year limitation period and all four equal-value factors all match.

The documentation threshold cannot be stated cleanly — the instrument gives it two ways, so an employer of 20 to 24 cannot tell from the text whether it is bound. Fines are criminal, €2,500 to €7,000, imposed by a court.

Status: Bill before parliament — plenary legislative debate set for 7 December 2026, with a further legislative session listed for 14 December.

There is still no Dutch start date: commencement is left to royal decree, and the draft implementing decree's own commencement article is blank.

First report 7 June 2028 for employers of 150 or more, and 7 June 2031 for 100 to 149.

What is measured is the payroll-tax wage. The annual figures are not corrected for part-time work and count employment relationships rather than people, and agency workers are reported by the hirer.

The works council consents to the job-evaluation criteria and to the pay evaluation and its action plan. The administrative fine does not reach unequal pay itself or the individual information right.

Status: Partial — recruitment duties in force since 24 December 2025. A complete transposition bill exists but has not reached the Council of Ministers.

Every employer recruiting under a contract of employment must give each candidate the initial pay or range plus applicable collective-agreement terms, and may not ask about pay in current or previous employment.

Nothing else is in force: no reporting duty, no individual information right, no joint pay assessment, and no fine for the duties that do bind.

The bill would commence six months after publication while fixing the first report for employers of 150 or more to 7 June 2027, so the deadline can fall due before the act binds anyone.

The bill has not moved since 4 May 2026. Equal value is still measured on three factors in the law in force; working conditions would be added only by the bill.

Status: Draft proposal, published in August 2026; public consultation closed on 25 August.

Reporting would start at 50 employees, half the Directive's floor, with agency workers counted in the headcount.

The reporting calendar is the Directive's own: 7 June 2027 for employers of 250 or more and of 150 to 249, and 7 June 2031 for 50 to 149.

Pay-secrecy clauses would be void, and the information right would extend expressly to temporary agency workers.

No revised text has appeared since the consultation closed, so the timing should be treated as soft. No Portuguese fine figure can be stated: the penalty scale sits in the Labour Code.

Status: Bill rejected by the Senate on 14 October 2026 and now before the Chamber of Deputies as the deciding chamber. Romania has missed the transposition deadline and has no pay transparency law.

There is no Romanian pay transparency law today: no reporting duty, no individual right to pay information, no joint pay assessment and no fine.

The bill was registered at the Chamber of Deputies on 19 October 2026. Amendments closed on 28 October and the committee report is due by 5 November.

The Chamber's human rights committee gave the bill a unanimous favourable opinion on 27 October 2026. The text before the Chamber is the one its initiators tabled; amendments proposed by Senate committees in October fell with the bill and are not law.

The penalty in that text is three to five times the national minimum gross wage, and five to ten times on repetition, on the wage in force when the fine is applied.

Status: In force since 7 June 2026 — and one compliance deadline has already passed.

Every employer that existed before 7 June 2026 had to have gender-neutral pay-setting criteria and pay structures in place by 31 July 2026. That date has passed and the duty is enforceable by the labour inspectorate.

The right to equal pay runs between workers of the same sex as well as between men and women.

First report 7 June 2027 for employers of 150 or more, over a five-month reference period from 1 August to 31 December 2026; the 100 to 149 band reports from 7 June 2031.

The ministry fines a reporting failure at €4,000 to €8,000 after a grace period of at least 15 days. The labour inspectorate fines the other duties and its ceiling sits in separate legislation, so no maximum can be stated.

Status: Draft with the Economic and Social Council since February 2026 — not tabled.

• A draft act was sent to the social partners in February 2026 and has not been tabled in parliament.

• Nothing has been opened on the public consultation portal or the legal register.

• No text has been located or read, so no provision can be stated.

• Slovenian employers have no national pay transparency obligation today.

Seven months with the social partners and no tabling is a slow-track signal rather than a neutral one.There is nothing to implement. Advice should rest on the Directive.

Status: Draft Royal Decree — consultation closed, not yet published in the official gazette.

The pay register binds every employer whatever its size and must carry both the mean and the median, in annual and hourly terms, component by component.

Reporting starts at 50 employees, on the Directive's own calendar: 7 June 2027 for employers of 150 or more and 7 June 2031 for 50 to 149.

The pay audit is unconditional for every employer of 50 or more, negotiated inside the equality plan, with unjustified gaps closed within six months. There is no 5% trigger.

The instrument contains nothing on recruitment and does not prohibit pay-confidentiality clauses. A dissolution of parliament does not suspend it, because it is a Royal Decree and has never been before the Cortes.

Status: No bill, and the Government has said it does not currently intend to introduce one.

• A fully drafted regime exists — a law council referral of 15 January 2026 proposing a new chapter in the Discrimination Act — but it has not been introduced.

• On 26 March 2026 the Government stated that it does not currently intend to lay a proposal and that it wants the Directive reopened at EU level. Nothing has moved since June 2026.

• The drafted regime is closely aligned: a two-month information right for every worker regardless of headcount, all seven metrics, and a three-year limitation period.

• On the drafted text, reports would go to the equality ombudsman by 20 May, first in 2027 for employers of 150 or more and in 2031 for 100 to 149.

• Swedish employers have no new national pay transparency obligation today, and Sweden has missed the transposition deadline.

The advice for Sweden has changed shape. It is no longer that a bill is coming and should be prepared for; it is that a drafted regime exists and the Government has said it does not currently intend to introduce it.

For a group with Swedish entities that means two things at once. Swedish entities should not be sequenced early in a group programme, because no Swedish obligation exists and may not for some time. But the drafted text remains the best available forecast of what Sweden would eventually enact, and it is close to the Directive, so designing to the Directive will not be wasted work.

Status of Transposition

Transposition deadline

All member states are required to have implemented the Directive by 7 June 2026.

Scope

Directive scope and coverage

The key measures introduced by the Directive are:

• Member states are required to establish gender pay gap reporting regimes, with company-wide results as well as results broken down by categories of workers. Employers must conduct a pay assessment where pay reporting reveals a gender pay gap of at least 5% in any category of workers that cannot be justified by objective and gender-neutral factors, and which has not been remedied within six months of submission of the report;

• Requirement to disclose the pay level or pay range for an advertised role to ensure pay transparency for jobseekers;

• A prohibition on asking job candidates about their current pay and pay history;

• Limits on the extent to which employers can control workers discussing their rate of pay;

• Increased transparency in setting rates of pay;

• A right to information about pay rates in an effort to ensure that workers are able to identify disparities; and

• The requirement to identify categories of workers for pay reporting, joint pay assessment and pay transparency purposes brings the concept of equal value to the forefront of the approach to equal pay in the EU.

Employer thresholds under the Directive

The Directive provides that employers with 100 or more workers must meet the reporting thresholds, but member states can implement reporting requirements on a phased basis should they wish:

• Employers with at least 150 workers must submit their first report in 2027;

• Employers with at least 250 workers must report annually thereafter;

• Employers with between 150-249 workers must report once every three years; and

• Member states may delay the first reporting for employers with between 100-149 workers to 2031.

Pay Transparency & Secrecy

Pay transparency obligations at recruitment stage

Prospective employers are obliged to give job applicants information about the initial pay or pay range for a particular position. The Directive provides that the information must be provided in a manner that ensures a transparent and informed negotiation on pay, such as "in a published job vacancy notice, prior to the job interview or otherwise".

Employers are not allowed to ask applicants about their pay history and must ensure that job adverts and job titles are gender neutral, with the recruitment process being led in a non-discriminatory manner. This right to information does not explicitly extend to internal applicants but is expressed to be incumbent on prospective employers only.

Employee right to request pay information

Workers have the right to request and receive, within two months, written information on their individual pay level and the average pay levels, broken down by sex, for categories of workers doing the same work or work for equal value during their employment. Employers are required to inform all workers of this right on an annual basis.

Pay secrecy clauses

Employers cannot prevent workers from disclosing their pay for the purpose of the enforcement of the principle of equal pay. In particular, member states are required to put in place measures to prohibit contractual terms that restrict workers from disclosing information about their pay.

Transparency on pay and pay progression criteria

Employers must make easily accessible to their workers the criteria that are used to determine workers’ pay, pay levels and pay progression. Those criteria shall be objective and gender neutral. Member states may exempt employers with fewer than 50 workers from that obligation.

Gender Pay Gap Reporting

Differences with the Gender Pay Gap Reporting metrics

N/A

Non-Compliance

Employee remedies

Member states must ensure that workers are entitled to unlimited compensation in respect of all of the losses sustained where their equal pay rights have been breached. This must include: full recovery of back pay and related bonuses or payments in kind (together with interest); compensation for lost opportunities; non-material damage; any damage caused by other relevant factors (which may include intersectional discrimination); and interest on arrears.

Penalties / enforcement mechanisms

Member states are required to put in place penalties for employers that break the rules and workers who have suffered gender pay discrimination can receive compensation. Member states must also establish specific penalties for infringements of the equal pay rule, including fines that guarantee a real deterrent effect.

Other Relevant Provisions

Categories of worker performing same work or work of equal value

Work of equal value is determined by taking the following factors into account:

• Objective, gender-neutral criteria should be used, and they should be agreed with workers’ representatives, where such representatives exist;

• The criteria should not be based directly or indirectly on workers’ sex;

• The objective criteria should include skills, effort, responsibility and working conditions. These factors have been identified as being essential and sufficient for evaluating the tasks performed in an organisation regardless of the economic sector to which the organisation operates. If appropriate, any other factors which are relevant to the specific job or position should be taken into account; and

• Relevant soft skills should not be undervalued in the process.