Implementation of the EU Pay Transparency Directive - New developments in France June 2026
June 09, 2026
Implementation of the EU Pay Transparency Directive - New developments in France June 2026June 09, 2026 “The new version of the bill confirms that the French transposition of the Pay Transparency Directive will go beyond a mere technical adjustment to the gender equality index. Employers will need to anticipate significant work on job classification, documentation of pay criteria and social dialogue.” Manon Lamotte, Partner Why should I read this?The EU Pay Transparency Directive (Directive (EU) 2023/970 of 10 May 2023) was required to be transposed by Member States by 7 June 2026. The French Ministry of Labour has shared a new version of the French transposition bill. This new version is significantly more advanced than the first draft and introduces several important changes. This briefing summarises the key aspects of the new draft, subject to adoption of the final text and the implementing decrees. Why do these developments matter?The first draft bill, circulated earlier this year, contained 9 articles divided into 2 titles. The public sector section had not yet been drafted, and the provision on public procurement referred to wording that was still “to come”. The new version contains 22 articles divided into 4 titles. It now comprehensively covers:
The draft confirms that France is taking an approach that is more demanding than the Directive in several respects: application from 50 employees, the central role of categorising work of equal value, significant involvement of employees representatives, and a strengthened sanctions regime which now includes a criminal component. At this stage, the text remains a draft and may still evolve during the legislative process. What you need to know about the new French bill?The key features of the new French draft bill are set out below.
What is likely to happen next?The text remains a draft and still needs to be adopted by Parliament. The transposition deadline has already passed; it is more likely that a final bill will be adopted by the end of 2026. Most provisions applicable to the private sector would enter into force on a date set by decree and, at the latest, one year after promulgation of the law. The indicator by category would be subject to a staggered timetable: no later than 3 years after promulgation for companies with 100 to 149 employees, and 6 years after promulgation for companies with 50 to 99 employees. Employees’ right to information on their level of pay and average pay levels would enter into force when the agreements or unilateral decisions setting the categories of workers enter into force. For the public sector, the provisions would enter into force one year after promulgation for employers managing at least 150 agents; 1 June 2030 for the others, subject to exceptions. Many aspects of the draft law remain subject to separate implementing decrees, the timing of which is not yet known. How we can helpOur 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 Diversidata product, our teams are ideally placed to help companies ensure legal compliance and transform their wider diversity and inclusion strategies. 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. Request access to our site here. Latest Insights
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