Malta’s Draft Pay Transparency Directive – Key Takeaways for Employers

Malta has released its first draft of regulations to implement the EU Pay Transparency Directive (EU 2023/970). Instead of introducing a brand-new law, Malta amends its existing Transparent and Predictable Working Conditions Regulations (under the Employment and Industrial Relations Act, Cap. 452). These changes—published as Legal Notice 112 of 2025—come into force on 27 August 2025. They signal Malta’s first formal step towards increased salary transparency, but the approach is incremental. The focus is on basic rights to pay information for job applicants and employees, with several more complex requirements left for future updates.

What’s changing?
The law now requires employers to provide pay information to job applicants before employment starts. This means you’ll need to disclose the initial salary, or a salary range, plus any relevant collective agreement pay clauses if the role is covered by a union or sectoral agreement. However, Malta’s draft does not go as far as some other EU countries—there’s no requirement to include salary in every job ad, and no explicit ban on asking candidates about their current or previous salary. While the EU Directive forbids such questions, Malta’s draft is silent on this point. Forward-thinking employers should consider stopping this practice anyway, as future amendments are likely.

For current employees, the law creates a right to request information about pay. Any employee can ask, in writing, for their own pay level and for the pay levels of colleagues performing the same work. Employers must provide this information within two months. Notably, the law covers “same work” but does not extend this right to information about roles of equal value (a broader concept used in the EU Directive), nor does it require the data to be broken down by gender. The definition is narrower than in the full Directive.

There are also important omissions compared to the full EU rules. Malta’s draft does not require companies to publish or report gender pay gap data (which the Directive demands from employers with 100+ staff starting in 2027). There’s no enforcement or penalty regime for non-compliance. There’s no obligation to publish the criteria for how pay is set or progressed, and no mention of bans on pay secrecy clauses or protections against retaliation for discussing pay. The law also skips the foundational EU concept of “work of equal value.”

In summary, Malta’s approach is to start with the basics: salary transparency before hiring, and a limited right for employees to compare pay with peers in identical jobs. The more demanding parts of the Directive—pay gap reporting, gender breakdowns, objective criteria for pay setting, and sanctions—will need further legislation before Malta achieves full compliance by the 7 June 2026 deadline.

What should employers do now?

Don’t wait for the next update. Begin preparing by:

Auditing your pay structure: Review pay levels across similar roles. Identify any gaps—especially those between men and women in the same role—and document explanations or plans for correction.
Documenting pay-setting criteria: Even if not required yet, have clear documentation for how pay and increases are determined. This helps future-proof your processes.
Updating recruitment and onboarding: Start standardizing how you share salary ranges or initial pay offers with candidates.
Preparing for information requests: Set up a process for responding to employee pay info requests quickly and accurately.
Communicating with staff: Let employees know that you are working towards compliance, and invite open dialogue on pay transparency.

Malta’s draft is a clear signal of the direction of travel. Full EU Pay Transparency Directive compliance is on the horizon. The most prepared organizations—those who audit their pay, clarify policies, and communicate openly—will not only avoid compliance headaches but also improve trust and employer branding.

For organizations wanting to automate all pay transparency compliance—across every EU member state—Sysarb provides a directive-native SaaS platform to streamline the process, cut manual work, and reduce consultancy costs.

References:

Malta has released its first draft of regulations to implement the EU Pay Transparency Directive (EU 2023/970). Instead of introducing a brand-new law, Malta amends its existing Transparent and Predictable Working Conditions Regulations (under the Employment and Industrial Relations Act, Cap. 452). These changes—published as Legal Notice 112 of 2025—come into force on 27 August 2025. They signal Malta’s first formal step towards increased salary transparency, but the approach is incremental. The focus is on basic rights to pay information for job applicants and employees, with several more complex requirements left for future updates.

What’s changing?
The law now requires employers to provide pay information to job applicants before employment starts. This means you’ll need to disclose the initial salary, or a salary range, plus any relevant collective agreement pay clauses if the role is covered by a union or sectoral agreement. However, Malta’s draft does not go as far as some other EU countries—there’s no requirement to include salary in every job ad, and no explicit ban on asking candidates about their current or previous salary. While the EU Directive forbids such questions, Malta’s draft is silent on this point. Forward-thinking employers should consider stopping this practice anyway, as future amendments are likely.

For current employees, the law creates a right to request information about pay. Any employee can ask, in writing, for their own pay level and for the pay levels of colleagues performing the same work. Employers must provide this information within two months. Notably, the law covers “same work” but does not extend this right to information about roles of equal value (a broader concept used in the EU Directive), nor does it require the data to be broken down by gender. The definition is narrower than in the full Directive.

There are also important omissions compared to the full EU rules. Malta’s draft does not require companies to publish or report gender pay gap data (which the Directive demands from employers with 100+ staff starting in 2027). There’s no enforcement or penalty regime for non-compliance. There’s no obligation to publish the criteria for how pay is set or progressed, and no mention of bans on pay secrecy clauses or protections against retaliation for discussing pay. The law also skips the foundational EU concept of “work of equal value.”

In summary, Malta’s approach is to start with the basics: salary transparency before hiring, and a limited right for employees to compare pay with peers in identical jobs. The more demanding parts of the Directive—pay gap reporting, gender breakdowns, objective criteria for pay setting, and sanctions—will need further legislation before Malta achieves full compliance by the 7 June 2026 deadline.

What should employers do now?

Don’t wait for the next update. Begin preparing by:

Auditing your pay structure: Review pay levels across similar roles. Identify any gaps—especially those between men and women in the same role—and document explanations or plans for correction.
Documenting pay-setting criteria: Even if not required yet, have clear documentation for how pay and increases are determined. This helps future-proof your processes.
Updating recruitment and onboarding: Start standardizing how you share salary ranges or initial pay offers with candidates.
Preparing for information requests: Set up a process for responding to employee pay info requests quickly and accurately.
Communicating with staff: Let employees know that you are working towards compliance, and invite open dialogue on pay transparency.

Malta’s draft is a clear signal of the direction of travel. Full EU Pay Transparency Directive compliance is on the horizon. The most prepared organizations—those who audit their pay, clarify policies, and communicate openly—will not only avoid compliance headaches but also improve trust and employer branding.

For organizations wanting to automate all pay transparency compliance—across every EU member state—Sysarb provides a directive-native SaaS platform to streamline the process, cut manual work, and reduce consultancy costs.

References:

Malta has released its first draft of regulations to implement the EU Pay Transparency Directive (EU 2023/970). Instead of introducing a brand-new law, Malta amends its existing Transparent and Predictable Working Conditions Regulations (under the Employment and Industrial Relations Act, Cap. 452). These changes—published as Legal Notice 112 of 2025—come into force on 27 August 2025. They signal Malta’s first formal step towards increased salary transparency, but the approach is incremental. The focus is on basic rights to pay information for job applicants and employees, with several more complex requirements left for future updates.

What’s changing?
The law now requires employers to provide pay information to job applicants before employment starts. This means you’ll need to disclose the initial salary, or a salary range, plus any relevant collective agreement pay clauses if the role is covered by a union or sectoral agreement. However, Malta’s draft does not go as far as some other EU countries—there’s no requirement to include salary in every job ad, and no explicit ban on asking candidates about their current or previous salary. While the EU Directive forbids such questions, Malta’s draft is silent on this point. Forward-thinking employers should consider stopping this practice anyway, as future amendments are likely.

For current employees, the law creates a right to request information about pay. Any employee can ask, in writing, for their own pay level and for the pay levels of colleagues performing the same work. Employers must provide this information within two months. Notably, the law covers “same work” but does not extend this right to information about roles of equal value (a broader concept used in the EU Directive), nor does it require the data to be broken down by gender. The definition is narrower than in the full Directive.

There are also important omissions compared to the full EU rules. Malta’s draft does not require companies to publish or report gender pay gap data (which the Directive demands from employers with 100+ staff starting in 2027). There’s no enforcement or penalty regime for non-compliance. There’s no obligation to publish the criteria for how pay is set or progressed, and no mention of bans on pay secrecy clauses or protections against retaliation for discussing pay. The law also skips the foundational EU concept of “work of equal value.”

In summary, Malta’s approach is to start with the basics: salary transparency before hiring, and a limited right for employees to compare pay with peers in identical jobs. The more demanding parts of the Directive—pay gap reporting, gender breakdowns, objective criteria for pay setting, and sanctions—will need further legislation before Malta achieves full compliance by the 7 June 2026 deadline.

What should employers do now?

Don’t wait for the next update. Begin preparing by:

Auditing your pay structure: Review pay levels across similar roles. Identify any gaps—especially those between men and women in the same role—and document explanations or plans for correction.
Documenting pay-setting criteria: Even if not required yet, have clear documentation for how pay and increases are determined. This helps future-proof your processes.
Updating recruitment and onboarding: Start standardizing how you share salary ranges or initial pay offers with candidates.
Preparing for information requests: Set up a process for responding to employee pay info requests quickly and accurately.
Communicating with staff: Let employees know that you are working towards compliance, and invite open dialogue on pay transparency.

Malta’s draft is a clear signal of the direction of travel. Full EU Pay Transparency Directive compliance is on the horizon. The most prepared organizations—those who audit their pay, clarify policies, and communicate openly—will not only avoid compliance headaches but also improve trust and employer branding.

For organizations wanting to automate all pay transparency compliance—across every EU member state—Sysarb provides a directive-native SaaS platform to streamline the process, cut manual work, and reduce consultancy costs.

References:

Malta has released its first draft of regulations to implement the EU Pay Transparency Directive (EU 2023/970). Instead of introducing a brand-new law, Malta amends its existing Transparent and Predictable Working Conditions Regulations (under the Employment and Industrial Relations Act, Cap. 452). These changes—published as Legal Notice 112 of 2025—come into force on 27 August 2025. They signal Malta’s first formal step towards increased salary transparency, but the approach is incremental. The focus is on basic rights to pay information for job applicants and employees, with several more complex requirements left for future updates.

What’s changing?
The law now requires employers to provide pay information to job applicants before employment starts. This means you’ll need to disclose the initial salary, or a salary range, plus any relevant collective agreement pay clauses if the role is covered by a union or sectoral agreement. However, Malta’s draft does not go as far as some other EU countries—there’s no requirement to include salary in every job ad, and no explicit ban on asking candidates about their current or previous salary. While the EU Directive forbids such questions, Malta’s draft is silent on this point. Forward-thinking employers should consider stopping this practice anyway, as future amendments are likely.

For current employees, the law creates a right to request information about pay. Any employee can ask, in writing, for their own pay level and for the pay levels of colleagues performing the same work. Employers must provide this information within two months. Notably, the law covers “same work” but does not extend this right to information about roles of equal value (a broader concept used in the EU Directive), nor does it require the data to be broken down by gender. The definition is narrower than in the full Directive.

There are also important omissions compared to the full EU rules. Malta’s draft does not require companies to publish or report gender pay gap data (which the Directive demands from employers with 100+ staff starting in 2027). There’s no enforcement or penalty regime for non-compliance. There’s no obligation to publish the criteria for how pay is set or progressed, and no mention of bans on pay secrecy clauses or protections against retaliation for discussing pay. The law also skips the foundational EU concept of “work of equal value.”

In summary, Malta’s approach is to start with the basics: salary transparency before hiring, and a limited right for employees to compare pay with peers in identical jobs. The more demanding parts of the Directive—pay gap reporting, gender breakdowns, objective criteria for pay setting, and sanctions—will need further legislation before Malta achieves full compliance by the 7 June 2026 deadline.

What should employers do now?

Don’t wait for the next update. Begin preparing by:

Auditing your pay structure: Review pay levels across similar roles. Identify any gaps—especially those between men and women in the same role—and document explanations or plans for correction.
Documenting pay-setting criteria: Even if not required yet, have clear documentation for how pay and increases are determined. This helps future-proof your processes.
Updating recruitment and onboarding: Start standardizing how you share salary ranges or initial pay offers with candidates.
Preparing for information requests: Set up a process for responding to employee pay info requests quickly and accurately.
Communicating with staff: Let employees know that you are working towards compliance, and invite open dialogue on pay transparency.

Malta’s draft is a clear signal of the direction of travel. Full EU Pay Transparency Directive compliance is on the horizon. The most prepared organizations—those who audit their pay, clarify policies, and communicate openly—will not only avoid compliance headaches but also improve trust and employer branding.

For organizations wanting to automate all pay transparency compliance—across every EU member state—Sysarb provides a directive-native SaaS platform to streamline the process, cut manual work, and reduce consultancy costs.

References:

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Malta’s Draft Pay Transparency Directive – Key Takeaways for Employers

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