EU Pay Transparency Directive: Snapshot update

With just over three months left before the 7 June 2026 transposition deadline, jurisdictions are beginning to increase their activities to progress towards implementation.

Planning for compliance with the Directive will typically be a cross-functional responsibility, including legal, HR, compensation, payroll and pay equity teams. Ensuring that a working group is established and identifying areas that may require external support will be essential.

With our established equal pay practice, we are ideally placed to support employers with pay transparency readiness, with some of our recent work in this respect including:

advising on how to structure the project to maximize privilege and the confidentiality of sensitive pay data and potential gaps
reviewing pay architecture through the lens of work of equal value to ensure compliance with the Directive
conducting pay gap analyses against current practices
advising on local legal developments
developing action plans
drafting EU consistent templates and processes
delivering training

Deadlines fast approaching

For those companies that have not yet taken any steps towards compliance, the time to act is now. Many of the Directive’s requirements will apply to all employers employing workers in the EU, regardless of their size and employee numbers, from 7 June 2026, or possibly earlier for those Members States choosing to commence new laws, or adjust existing ones, before that date. Countries in this latter category currently include Belgium (where parts of the Directive have already been brought into force for the French Community of the public sector since 1 January 2025), the Czech Republic (where a ban on pay‑secrecy clauses took effect on 1 June 2025), Poland (where some pay‑transparency obligations at the recruitment stage already took effect from 24 December 2025) and Finland (where the planned enactment date is currently 18 May 2026).

The “day one” requirements that apply to all employers include pay transparency for applicants, making pay setting and pay progression criteria accessible to existing workers, and providing workers with average pay data for categories of workers performing the same work as them or work of equal value to theirs. Establishing suitable pay arrangements and HR processes to comply with these requirements requires careful planning and sufficient time.

In accordance with the Directive, reporting on pay gaps will commence from 2027 for employers with 150 workers or more. For those employers, the urgency for action is further heightened, as the reporting of pay gap figures in 2027 must be based on data for the period 1 January 2026 to 31 December 2026.

Early signals of areas of variation

Many Member States have yet to publish their legislation that will implement the Directive. Of those that have taken measures, no Member State has yet fully transposed the Directive. A summary of those Member States where there have been developments is set out at the end of this briefing.

Areas of variation in local implementation are already being seen from those jurisdictions that have transposed some elements of the Directive, or in draft laws. In some areas, the Directive gives express scope for Member States to develop their own measures to implement the Directive’s minimum requirements. In other areas, the wide drafting of the Directive gives scope for Member States to apply their own interpretations or add additional rules.

An example is pay transparency for applicants. Potential areas of variation in local implementation, and where some differences in application have already been seen, include in relation to the meaning of initial salary, the application of any constraints on overly-wide pay ranges, whether information must be provided proactively or reactively, and in the manner and timing of providing the information.

Will the 7 June 2026 transposition deadline be met?

The European Commission confirmed on 18 December 2025 that it expects all Member States to transpose the Directive by the deadline of 7 June 2026.

As noted above, progress on national implementation has been uneven to date. Many Member States have confirmed that they are working towards the implementation deadline, with some Member States already having new laws in place to partially transpose the Directive’s requirements. The Netherlands and Denmark have confirmed that they will miss the deadline, instead aiming to have their new legislation in force by 1 January 2027. Sweden is aiming for its legislative amendments implementing the Directive to enter into force on 1 July 2026.

Failure to transpose the Directive by the deadline can have significant implications, including the potential direct effect of EU rules and infringement procedures being pursued against Member States by the European Commission. As was seen when some Member States missed the deadline for transposing the Whistleblowing Directive, such infringement action can result in significant fines. Consequently, it is anticipated that Member Staes will be keen to ensure that they have enacted compliant legislation within the required timeframe.

Supporting you with pay transparency readiness

Our extensive global footprint and our established equal pay practice means that we are well placed to support global employers in getting ready for pay transparency compliance, wherever they have a presence. Our lawyers are not only experts in the complexities of different laws, but also in the management of projects spanning jurisdictions and driving those projects to maximize the strategic aims and benefits. With the added benefit of our internal tools that allow us to track and respond to ongoing developments, as well as our Diversidataproduct, our teams are ideally placed to help companies ensure legal compliance and transform their wider diversity and inclusion strategies.

Look out for details of our pay transparency events, designed to support companies with their pay transparency readiness..

Local transposition progress – a snapshot

You can track the latest developments on our Navigating Global Pay interactive site, as well as access to essential FAQs, timelines, a summary of the Directive, a glossary and briefings. You can request access to our site here.

Member State	Steps towards transposition
Belgium	At regional level, a decree applicable to employers within the public sector of the French Community in Belgium made changes which took effect on 1 January 2025 that aligns the current legislative framework with some elements of the Directive. On 26 January 2026, a proposal for a Resolution relating to pay transparency was formally submitted to the Belgian House of Representatives by members of the N-VA party. The Resolution is a non-binding political request calling on the federal government to take a minimal-intervention approach to transposing the Directive.
Cyprus	The Department of Labor Relations of the Ministry of Labor and Social Insurance has consulted on a draft bill to transpose the Directive. That consultation is now closed and the outcome is awaited.
Denmark	The Danish government sent a bill for external consultation on 26 February 2026, proposing a comprehensive reform of the existing Danish Equal Pay Act. Implementation is set to the later date of 1 January 2027 and the first report for companies with 150 or more employees is 1 September 2028. The consultation deadline is 27 March 2026, although due to elections in Denmark, it is currently unclear when the next step in the process will take place.
Finland	A tripartite working group appointed by the Ministry of Social Affairs and Health has completed a draft proposal for the national implementation of the Directive, which was published on 16 May 2025. The Ministry of Social Affairs and Health requested comments on the draft proposal by 9 February 2026 and the outcome is awaited. The Government proposal is expected to be submitted to Parliament in March 2026 (week 11/2026). Once submitted, the proposal will undergo parliamentary review, debate and voting before enactment.
France	The French Ministry of Labour has announced that multilateral consultations will now take place to finalize a text to transpose the Directive. On 14 May 2025, the Labor Minister confirmed changes to the current gender equality index in 2027 as part of the plan to transpose the Directive. A meeting was held on 15 January 2026 between the Ministry of Labour and trade unions to progress the Directive’s implementation. A further meeting was scheduled for 29 January 2026 at which a draft bill was expected to be presented, but was delayed. There is currently no confirmed date when the new legislation will come into force.
Germany	A commission has been established to assess low-bureaucracy implementation of the Directive and to develop proposals to align German law with the Directive. The commission has now published its report, consisting of a number of opinions of the commission on elements including the definition of remuneration for reporting purposes, the calculation of the gender pay gap, how supplementary and variable remuneration components should be reported, and whether the law should differ for companies that apply collective agreements. The next step is that the legislative procedure will now be initiated, including the draft law being published in due course.
Greece	The process of setting up a working group for the transposition of the Directive has been initiated.
Ireland	Gender pay gap reporting obligations already exist. As of 1 June 2025, the threshold for reporting was lowered to employers with 50+ employees. A Bill is in progress aimed at partly transposing the Directive in relation to the recruitment stage, with the Bill at the second stage in the Seanad. The legislative programme notes that “heads are in preparation” for a separate Bill to transpose the remaining aspects of the Directive, meaning that the initial draft framework for the Bill is underway.
Italy	A draft legislative decree to implement the Directive was presented to trade unions and employer groups on 3 February 2026, and is expected to go before the Council of Ministers before moving through the parliamentary approval process.
Latvia	According to the latest publicly available information from the Ministry of Welfare, work is actively underway to transpose the Directive’s requirements, both by developing an appropriate legal framework and implementing additional measures to ensure full compliance.
Lithuania	In May 2025, the Ministry of Social Security and Labour published a proposal for the (partial) implementation of the Directive. Following consultation on the proposal, a draft amendment to the Lithuanian Labour Code has been registered, with the target date for implementation being 7 June 2026. That draft amendment is generally aligned with the requirements of the Directive (with several secondary acts expected to further set reporting formats, procedures etc.). However, the draft has now been returned to the Ministry of Social Security and Labour for further improvement.
Malta	New Regulations came into force on 27 August 2025, limited to transposing the elements of the Directive concerning pay transparency at the recruitment stage and the right of workers to request their individual pay level and the pay levels for categories of workers performing the same work as them. The Regulations do not cover the remaining elements of the Directive, in respect of which draft legislation has not yet been published.
Netherlands	Consultation regarding proposed legislation for the implementation of the Directive closed on 7 May 2025. The draft proposal (including the legislative text and Explanatory Memorandum) has now been submitted to the Dutch Council of State. The Dutch government has confirmed that the new legislation will come into force by 1 January 2027 and that the first reporting obligation for employers with 150 or more employees will apply to pay data for the calendar year 2027.
Poland	An Act amending the Labour Code came into force on 24 December 2025, limited to transposing the elements of the Directive concerning pay transparency at the recruitment stage. On 16 December 2025, the Polish government published a draft law to transpose the remaining elements of the Directive.
Portugal	The Commission for Equality in Labour and Employment is consulting with social partners to present the Government with an assessment regarding the future transposition of the Directive.
Romania	No draft law has yet been published. However, it is understood that this is progressing, with public consultation planned once the draft law is finalized. The law transposing the Directive is expected to be published in the Official Gazette (Monitorul Oficial) during the first semester of 2026.
Slovakia	On 19 September 2025, Slovakia published a draft of its legislation to transpose the requirements of the Directive, and has confirmed that it is aiming for an implementation date of 1 June 2026. The draft introduces a standalone law, and also amends related laws such as the Labor Code, Labor Inspection Act, and the Employment Services Act. The draft was open for public comment and additional review until 9 October 2025. The draft law was delivered to the Slovak Parliament on 7 January 2026 and is currently under parliamentary negotiation.
Slovenia	The Ministry of Labour, Family, Social Affairs and Equal Opportunities has set up a working group to work on the implementation of the Directive.
Sweden	The Swedish government has initiated an investigation into what changes need to be made to Swedish law to transpose the Directive, and an inquiry report has been issued. On 15 January 2026, the government referred a legislative proposal to the Council on Legislation and intends to submit a bill to the parliament in the spring. In the referral to the Council on Legislation, the government proposes that the legislative amendments implementing the Directive should enter into force on 1 July 2026.

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