EU Pay Transparency Directive

With less than 120 working days to go before transparency requirements come into effect, the time to progress readiness for compliance is now. We would love to be part of your EU Pay Transparency journey – and can help, so please feel free to reach out. 

This review provides a concise summary of the key developments to date, helping you understand the evolving landscape and prepare for upcoming compliance obligations.

Executive summary
We note, that in Denmark, the implementation of the EU PTD is not included in the government’s legislative program for the parliamentary year 2025-2026. This suggests that Denmark will not meet the deadline to implement the directive by 7 June 2026. Accordingly, we have not included Denmark in the below summary.

2025 transposition highlights per country
In Belgium, partial implementation has been achieved with legislation in force for the public sector within the French Community since 1 January 2025. This initial, yet partial, transposition focuses on pay transparency at recruitment, including the requirement to disclose pay levels or ranges in job advertisements before interviews, and assessments related to family leave affecting pay progression. The Flemish Community has approved a draft bill for public sector application, which is pending parliamentary approval. Both communities apply these rules specifically to public companies under their responsibility, reflecting a narrower scope than the Directive’s full coverage.

Czechia has partially implemented the Directive by banning pay secrecy clauses effective from 1 June 2025, allowing employees to freely discuss their pay. Other aspects of the Directive, such as pay transparency obligations at recruitment and gender pay gap reporting, remain under development with draft legislation expected.

In Finland, a draft bill currently before parliament aims for a “pure implementation” closely aligned with the Directive. It requires disclosure of initial pay levels or ranges before interviews and prohibits salary history inquiries. The draft also mandates gender pay gap reporting for employers with 250 or more employees annually, and every three years for those with 100 to 249 employees. Employers with 50 or more employees must provide accessible, objective, and gender-neutral criteria for pay and progression.

Germany has not yet fully implemented the Directive but made progress with the publication of a Commission report in November 2025. The report offers recommendations on reducing bureaucracy and aligning existing legislation with the Directive, including proposals on reporting based on actual pay and a somewhat controversial recommendation that there should be a presumption of adequacy for collective bargaining agreements. A draft bill is expected in early 2026. Meanwhile, a recent Federal Labour Court ruling has heightened employer risks related to pay discrimination claims.Ireland has published a draft bill for partial implementation focusing on recruitment transparency. The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 requires employers to include salary ranges in job advertisements and prohibits questions about applicants’ pay history. The bill also mandates that employers make pay and progression criteria easily accessible to workers, though further details on enforcement and reporting remain pending.

Lithuania has presented draft proposals to the Ministry of Social Security aiming for partial implementation of pay transparency measures. Existing Labour Code provisions already meet some Directive requirements, such as mandatory pay information in job postings and gender pay gap reporting for employers with 20 or more employees. The draft legislation extends pay structure obligations and prohibits salary history inquiries, with fines for non-compliance.

In Malta, legislation effective from 27 August 2025 partially implements the Directive, focusing on recruitment transparency. Employers must disclose starting salaries or salary ranges before employment, and employees have the right to request pay information within two months. However, the scope of comparison rights is narrower than the Directive, limited to employees performing the same work.

The Netherlands remains in the consultation phase, with total implementation planned by 1 January 2027. The government states that it has opted for a “pure implementation” approach, adhering closely to the Directive’s minimum requirements, however in reality there are elements of gold-plating, for example the definition of “worker” includes anyone under the company’s supervision or direction which would include agency workers, meaning that companies would need to report the gender pay gap for such agency workers. In addition, worker representatives will be given a veto right over categorization of workers and the objective and gender-neutral criteria applied. Employers will be required to disclose starting pay or pay ranges in job postings or before interviews, and salary history questions will be prohibited. Employers with 50 or more employees must provide accessible, objective pay progression criteria, and gender pay gap reporting thresholds will follow the Directive’s phased approach.

Poland enacted legislation effective 24 December 2025, partially transposing the Directive by focusing on recruitment transparency. Employers must provide salary information before interviews and are prohibited from asking about salary history. Broader pay transparency and reporting obligations remain under development.

Sweden already has a legal framework that meets the Directive’s reporting requirements. The government published a report on family leave’s impact on pay progression, and draft legislation proposes amendments to the Discrimination Act to integrate the Directive’s provisions. The approach extends reporting obligations to employers with as few as 10 employees, exceeding the Directive’s minimum thresholds.

Finally, Slovakia published a draft bill broadly aligned with the Directive, expected to come into force by June 2026. The bill applies to both public and private sectors, including judges, and requires employers to publish pay bands and criteria. Employees and their representatives have rights to request pay information, and penalties for non-compliance are set at up to €4,000 per breach.

Looking ahead
All Member States must complete transposition by June 2026. We see that most countries which have produced draft legislation currently only opted for a partial transposition of the Directive. Recruitment transparency, salary history bans and salary disclosure requirements have been most commonly adopted so far. Where gender pay gap reporting has been enacted or proposed in draft legislation, the thresholds typically follow the Directive’s guidelines. Enforcement mechanisms vary across jurisdictions and remain under development in several countries.

Employers should monitor developments closely, particularly regarding reporting obligations, employee rights to pay information, and enforcement. However, we recommend not awaiting final legislation before commencing your preparations, as several member states are likely to publish their draft legislation only shortly before the implementation date and employers have significant work to do to ensure readiness for the Directive. Clients are currently reviewing their pay gaps and understanding any remediation required as well as reviewing pay (transparency) policies and preparing for upcoming reporting and disclosure requirements in jurisdictions of operation.

Should you require tailored advice or support on compliance with the EU Pay Transparency Directive, please do not hesitate to contact me.