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Sysarb's Global Pay Transparency Tracker
Sysarb's Global Pay Transparency Tracker
This tracker helps you to understand pay transparency and equal pay obligations across the globe.
This tracker helps you to understand pay transparency and equal pay obligations across the globe.
Austria
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Austria has not publicly signalled any transposition activity. Employers operating in Austria should monitor developments closely, as a compressed timeline is likely once legislative work begins.
Bulgaria
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress. Employers with Bulgarian operations should prepare based on the Directive's baseline requirements.
Cyprus
Progress: Proposal published.
Proposal: Yes (5 November 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Department of Labor Relations published a draft bill in November 2025 covering equal pay through wage transparency and enforcement mechanisms.
What makes Cyprus notable:
Clean transposition that sticks closely to the Directive's baseline without materially tightening thresholds or timelines
Joint pay assessments must specifically examine whether employees returning from parental, maternity, paternity, or carers' leave benefited from pay increases granted in their worker category during their absence
Strong enforcement architecture including fines, criminal liability, and a decisive shift in the burden of proof to employers where transparency obligations are breached
Denmark
Progress: Proposal published.
Proposal: Yes (26 February 2026).
Adopted law: No.
Applies from: Not yet set (proposal targets 1 January 2027).
Denmark published a draft law amending the Equal Pay Act for consultation on 26 February 2026. The government has openly acknowledged that it will delay implementation beyond the June 2026 deadline, prioritizing administrative alignment and data integrity.
What makes Denmark notable:
Implementation delayed to 1 January 2027, with the first Directive-aligned reports due in September 2028
Employer-friendly approach with no significant "gold plating" beyond what the Directive requires
Statistics Denmark will prepare reports for employers with 150 or more employees using DISCO codes. Employers with 100 to 149 employees will first report in 2031
No requirement to include pay ranges in job postings
Limited reporting for employers with 50 to 99 employees where at least 8 employees of each gender fall within the same 6-digit DISCO group
Estonia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Head of Gender Equality Policy has indicated that the draft needed to transpose the Directive is being prepared.
Germany
Progress: Commission report published, legislative process starting.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Germany formed an 11-person Commission in July 2025 to develop a "bureaucracy-reduced" implementation model. The Commission published its final report on 7 November 2025 and submitted it to the Federal Ministry for Gender Equality. The Ministry will now initiate the formal legislative process. There is no draft law yet.
What makes Germany notable:
Pay gap reporting would be based on actual pay from 2026 payroll data, not targets. The reporting threshold is recommended at 100 employees
Outliers such as severance pay would be excluded, and de minimis exemptions would apply for small in-kind benefits
Right to information is recommended to apply from 2027. Data from comparison groups with fewer than six men and six women would not be shared with employees due to privacy protections
Employers would be required to include a clear description of how each "category of worker" is formed in the right to information report
Hungary
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Italy
Progress: Proposal published.
Proposal: Yes (3 February 2026).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Italy passed Legge n. 15/2024 in February 2024, which mandated the government to issue implementing decrees before the June 2026 deadline. A transposition draft was issued on 3 February 2026.
What makes Italy notable:
"Categories of workers" are primarily defined by collective bargaining classification systems (CCNL) rather than employer-designed job families. Comparability flows from contractual levels negotiated at sector level
Harder at hiring: job applicants must receive detailed pay structure information directly in job advertisements. Easier at scale: employers with 100 or more employees can publish Right to Information data on an intranet or restricted website instead of responding to each request individually
Country-level pay gap reporting is allowed where a unified group pay policy applies, rather than requiring legal-entity-by-entity reporting
Luxembourg
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour indicated on 17 November 2025 that a draft bill will be submitted to the Government Council.
Lithuania
Progress: Proposal published.
Proposal: Yes (27 May 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Social Security and Labour presented a full transposition draft to the Tripartite Council on 27 May 2025, covering employer associations, trade unions, and the government.
What makes Lithuania notable:
Extends existing reporting requirements. Lithuania's Social Security institution already publishes monthly average pay gap data. Under the draft, employees can now request job-category-level gap data once a year. If the gap exceeds five percent, employers must explain or fix it
The collective agreement applicable to the position must be provided before discussing or signing the employment contract
Every employer regardless of size must now co-develop formal, gender-neutral pay structures. Previously, this only applied to companies with 20 or more staff
Poland
Progress: Partial law in force, remaining obligations in proposal.
Proposal: Yes (16 December 2025, for remaining portions).
Adopted law: Yes, partial (pay range transparency and gender-neutral job titles, 23 June 2025).
Applies from: 24 December 2025 (partial).
Poland split its implementation into stages. Pay range transparency and gender-neutral job titles were enacted on 23 June 2025 and took effect on 24 December 2025. Draft legislation for the remaining Directive obligations was published on 16 December 2025.
What makes Poland notable:
Right to information response deadline tightened to 30 days, compared to 60 days under the Directive
Employers must notify employees by 31 March each year of their right to request pay information
Pay gap reports due by 31 March. If a trade union or equality body requests explanations, employers have only 14 days to respond
Romania
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Slovenia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour, Family, Social Affairs and Equal Opportunities is working on implementation together with project partners including the Faculty of Economics at the University of Ljubljana and the Diversity Charter of Slovenia.
Spain
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No official announcement yet, but there are indications that a draft is in process.
Belgium
Progress: Partial transposition (regional).
Proposal: Yes (for FWB region); coming for rest of Belgium.
Adopted law: Yes (Fédération Wallonie-Bruxelles only, 12 September 2024).
Applies from: 2026.
Belgium became the first EU member state to transpose the Directive when the Fédération Wallonie-Bruxelles adopted it in September 2024. However, this only covers approximately 7,500 mostly public-sector employees. On 26 January 2026, the House of Representatives issued a resolution calling on the federal government to implement the Directive across Belgium. The government committed to doing so.
What makes Belgium notable:
First transposition in the EU, but limited to one regional jurisdiction
Pay ranges must be disclosed as soon as job offers or advertisements are published, going further than the Directive requires
Employers must report on the impact of family-related leaves on remuneration, broken down by gender and leave type
Croatia
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Czechia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour and Social Affairs has indicated that a draft is in process. Czechia has already taken a partial step: the "flexi-amendment" to the Labour Code banned pay secrecy from 1 June 2025.
Finland
Progress: Proposal published.
Proposal: Yes (16 May 2025, updated December 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Finland published a draft in May 2025 addressing pay transparency and reporting. In December 2025, the Ministry of Social Affairs and Health requested formal statements on a government proposal, with comments due by 9 February 2026.
What makes Finland notable:
Three-layer reporting system: the government will calculate overall pay gaps for employers with 100 or more workers using existing payroll data, but employers remain responsible for analyzing results by category of worker. Existing pay audit obligations for companies with 30 or more employees (every two years as part of their Gender Equality Plan) also continue
Pay gap data will be centered on taxable earnings, offering the clearest signal yet of what data will be required
Privacy concerns have been flagged but not resolved. There is no numerical threshold for when pay information should be shared with the works council instead of all employees
France
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The French government launched formal consultations with trade unions and employer federations in May 2025. A draft was scheduled for release in late January 2026.
Greece
Progress: Early stages.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No official announcement yet, but the process to set up a working group has begun.
Ireland
Progress: Partial proposal published.
Proposal: Yes, but only for pay transparency (15 January 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Ireland's draft addresses pre-employment transparency only. Pay gap reporting and other requirements of the Directive are not yet covered.
What makes Ireland notable:
Pay ranges must be included in job advertisements, going beyond the minimum requirement of the Directive
Salary history ban aligned with the Directive
Pay gap reporting, right to information, and other core obligations are still missing from the draft
Latvia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Welfare has confirmed that Latvia plans to adopt the minimum requirements of the Directive through a new, separate law. Work is underway on both the legal framework and supporting implementation measures.
Malta
Progress: Partial law in force.
Proposal: Yes (partial).
Adopted law: Yes (partial, 27 June 2025).
Applies from: 27 August 2025 (pay range transparency and right to information only).
Malta passed legislation transposing selective portions of the pay transparency and right to information provisions on 27 June 2025. These took effect on 27 August 2025. The remaining Directive requirements are still pending.
What makes Malta notable:
Earliest effective date in the EU, a full ten months before the deadline, but with narrow scope covering only pre-employment transparency and right to information
Employers can delay disclosing pay ranges and applicable collective agreements until just before the job starts
Right to information is limited to average pay for same work only. There is no right to know pay for "work of equal value" as required by the Directive. Employers have 60 days to respond
Netherlands
Progress: Proposal published, delayed implementation.
Proposal: Yes (25 March 2025, updated 19 January 2026).
Adopted law: No.
Applies from: Likely 1 January 2027.
The Dutch government issued a draft in March 2025 and sent the wage transparency bill to the Council of State on 19 January 2026. However, the Minister of Social Affairs and Employment has confirmed that the Netherlands is not likely to meet the June 2026 deadline. Entry into force is expected by 1 January 2027.
What makes the Netherlands notable:
Closest to a clean implementation of the Directive among all member states
Employers with 150 or more employees will first report on 2027 pay data, likely in June 2028. Employers with 100 to 149 employees will report in June 2031 on 2030 data
Broad definition of pay. Only employer-wide costs not tracked at the individual level are excluded
Controversial provision: temporary agency workers may be counted in the pay gap data of the host company rather than the staffing agency. This sparked significant criticism during public consultation
Portugal
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Slovakia
Progress: Proposal in parliamentary process.
Proposal: Yes (19 September 2025, updated 6 January 2026).
Adopted law: No.
Applies from: Expected 1 June 2026.
Slovakia's draft was formally submitted to the National Council on 6 January 2026 for parliamentary consideration. The government has confirmed the goal is clean, on-time transposition.
What makes Slovakia notable:
Full-scope implementation covering both transparency and reporting requirements, expected to take effect on 1 June 2026
Introduces a 15 April deadline for filing pay gap reports
Provides helpful guidance on grouping employees by the value of their work, applying career progression criteria, and what counts as a legitimate reason for pay differences. The definition of pay is broad, covering bonuses, benefits, and in-kind compensation
Sweden
Progress: Proposal published (most detailed in the EU).
Proposal: Yes (May 2024, updated 15 January 2026).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Sweden was the first member state to publish draft legislation in May 2024, delivering the most detailed article-by-article proposal to date. An updated draft titled "Genomförande av lönetransparensdirektivet" was formally referred to the Council on Legislation on 15 January 2026. In April 2025, the Ministry of Labour allocated 10 million SEK for the development of a platform to collect pay reporting data.
What makes Sweden notable:
Two-track reporting system. Employers with 100 or more employees must publish EU Directive-aligned pay gap reports while also continuing Sweden's national pay analyses covering equal work, equal value, and lesser value. Written documentation is required from 25 or more employees
New obligation to analyze pay development following family-related leave
Right to information can be met using existing annual pay analyses. There is no requirement to refresh data outside the annual cycle
The 2026 draft is more complex than the 2024 version. Rather than simplifying, it adds obligations on top of Sweden's existing regime
Austria
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Austria has not publicly signalled any transposition activity. Employers operating in Austria should monitor developments closely, as a compressed timeline is likely once legislative work begins.
Belgium
Progress: Partial transposition (regional).
Proposal: Yes (for FWB region); coming for rest of Belgium.
Adopted law: Yes (Fédération Wallonie-Bruxelles only, 12 September 2024).
Applies from: 2026.
Belgium became the first EU member state to transpose the Directive when the Fédération Wallonie-Bruxelles adopted it in September 2024. However, this only covers approximately 7,500 mostly public-sector employees. On 26 January 2026, the House of Representatives issued a resolution calling on the federal government to implement the Directive across Belgium. The government committed to doing so.
What makes Belgium notable:
First transposition in the EU, but limited to one regional jurisdiction
Pay ranges must be disclosed as soon as job offers or advertisements are published, going further than the Directive requires
Employers must report on the impact of family-related leaves on remuneration, broken down by gender and leave type
Croatia
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Bulgaria
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress. Employers with Bulgarian operations should prepare based on the Directive's baseline requirements.
Czechia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour and Social Affairs has indicated that a draft is in process. Czechia has already taken a partial step: the "flexi-amendment" to the Labour Code banned pay secrecy from 1 June 2025.
Cyprus
Progress: Proposal published.
Proposal: Yes (5 November 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Department of Labor Relations published a draft bill in November 2025 covering equal pay through wage transparency and enforcement mechanisms.
What makes Cyprus notable:
Clean transposition that sticks closely to the Directive's baseline without materially tightening thresholds or timelines
Joint pay assessments must specifically examine whether employees returning from parental, maternity, paternity, or carers' leave benefited from pay increases granted in their worker category during their absence
Strong enforcement architecture including fines, criminal liability, and a decisive shift in the burden of proof to employers where transparency obligations are breached
Estonia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Head of Gender Equality Policy has indicated that the draft needed to transpose the Directive is being prepared.
Denmark
Progress: Proposal published.
Proposal: Yes (26 February 2026).
Adopted law: No.
Applies from: Not yet set (proposal targets 1 January 2027).
Denmark published a draft law amending the Equal Pay Act for consultation on 26 February 2026. The government has openly acknowledged that it will delay implementation beyond the June 2026 deadline, prioritizing administrative alignment and data integrity.
What makes Denmark notable:
Implementation delayed to 1 January 2027, with the first Directive-aligned reports due in September 2028
Employer-friendly approach with no significant "gold plating" beyond what the Directive requires
Statistics Denmark will prepare reports for employers with 150 or more employees using DISCO codes. Employers with 100 to 149 employees will first report in 2031
No requirement to include pay ranges in job postings
Limited reporting for employers with 50 to 99 employees where at least 8 employees of each gender fall within the same 6-digit DISCO group
Finland
Progress: Proposal published.
Proposal: Yes (16 May 2025, updated December 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Finland published a draft in May 2025 addressing pay transparency and reporting. In December 2025, the Ministry of Social Affairs and Health requested formal statements on a government proposal, with comments due by 9 February 2026.
What makes Finland notable:
Three-layer reporting system: the government will calculate overall pay gaps for employers with 100 or more workers using existing payroll data, but employers remain responsible for analyzing results by category of worker. Existing pay audit obligations for companies with 30 or more employees (every two years as part of their Gender Equality Plan) also continue
Pay gap data will be centered on taxable earnings, offering the clearest signal yet of what data will be required
Privacy concerns have been flagged but not resolved. There is no numerical threshold for when pay information should be shared with the works council instead of all employees
France
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The French government launched formal consultations with trade unions and employer federations in May 2025. A draft was scheduled for release in late January 2026.
Greece
Progress: Early stages.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No official announcement yet, but the process to set up a working group has begun.
Ireland
Progress: Partial proposal published.
Proposal: Yes, but only for pay transparency (15 January 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Ireland's draft addresses pre-employment transparency only. Pay gap reporting and other requirements of the Directive are not yet covered.
What makes Ireland notable:
Pay ranges must be included in job advertisements, going beyond the minimum requirement of the Directive
Salary history ban aligned with the Directive
Pay gap reporting, right to information, and other core obligations are still missing from the draft
Germany
Progress: Commission report published, legislative process starting.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Germany formed an 11-person Commission in July 2025 to develop a "bureaucracy-reduced" implementation model. The Commission published its final report on 7 November 2025 and submitted it to the Federal Ministry for Gender Equality. The Ministry will now initiate the formal legislative process. There is no draft law yet.
What makes Germany notable:
Pay gap reporting would be based on actual pay from 2026 payroll data, not targets. The reporting threshold is recommended at 100 employees
Outliers such as severance pay would be excluded, and de minimis exemptions would apply for small in-kind benefits
Right to information is recommended to apply from 2027. Data from comparison groups with fewer than six men and six women would not be shared with employees due to privacy protections
Employers would be required to include a clear description of how each "category of worker" is formed in the right to information report
Italy
Progress: Proposal published.
Proposal: Yes (3 February 2026).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Italy passed Legge n. 15/2024 in February 2024, which mandated the government to issue implementing decrees before the June 2026 deadline. A transposition draft was issued on 3 February 2026.
What makes Italy notable:
"Categories of workers" are primarily defined by collective bargaining classification systems (CCNL) rather than employer-designed job families. Comparability flows from contractual levels negotiated at sector level
Harder at hiring: job applicants must receive detailed pay structure information directly in job advertisements. Easier at scale: employers with 100 or more employees can publish Right to Information data on an intranet or restricted website instead of responding to each request individually
Country-level pay gap reporting is allowed where a unified group pay policy applies, rather than requiring legal-entity-by-entity reporting
Hungary
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Latvia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Welfare has confirmed that Latvia plans to adopt the minimum requirements of the Directive through a new, separate law. Work is underway on both the legal framework and supporting implementation measures.
Luxembourg
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour indicated on 17 November 2025 that a draft bill will be submitted to the Government Council.
Netherlands
Progress: Proposal published, delayed implementation.
Proposal: Yes (25 March 2025, updated 19 January 2026).
Adopted law: No.
Applies from: Likely 1 January 2027.
The Dutch government issued a draft in March 2025 and sent the wage transparency bill to the Council of State on 19 January 2026. However, the Minister of Social Affairs and Employment has confirmed that the Netherlands is not likely to meet the June 2026 deadline. Entry into force is expected by 1 January 2027.
What makes the Netherlands notable:
Closest to a clean implementation of the Directive among all member states
Employers with 150 or more employees will first report on 2027 pay data, likely in June 2028. Employers with 100 to 149 employees will report in June 2031 on 2030 data
Broad definition of pay. Only employer-wide costs not tracked at the individual level are excluded
Controversial provision: temporary agency workers may be counted in the pay gap data of the host company rather than the staffing agency. This sparked significant criticism during public consultation
Malta
Progress: Partial law in force.
Proposal: Yes (partial).
Adopted law: Yes (partial, 27 June 2025).
Applies from: 27 August 2025 (pay range transparency and right to information only).
Malta passed legislation transposing selective portions of the pay transparency and right to information provisions on 27 June 2025. These took effect on 27 August 2025. The remaining Directive requirements are still pending.
What makes Malta notable:
Earliest effective date in the EU, a full ten months before the deadline, but with narrow scope covering only pre-employment transparency and right to information
Employers can delay disclosing pay ranges and applicable collective agreements until just before the job starts
Right to information is limited to average pay for same work only. There is no right to know pay for "work of equal value" as required by the Directive. Employers have 60 days to respond
Lithuania
Progress: Proposal published.
Proposal: Yes (27 May 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Social Security and Labour presented a full transposition draft to the Tripartite Council on 27 May 2025, covering employer associations, trade unions, and the government.
What makes Lithuania notable:
Extends existing reporting requirements. Lithuania's Social Security institution already publishes monthly average pay gap data. Under the draft, employees can now request job-category-level gap data once a year. If the gap exceeds five percent, employers must explain or fix it
The collective agreement applicable to the position must be provided before discussing or signing the employment contract
Every employer regardless of size must now co-develop formal, gender-neutral pay structures. Previously, this only applied to companies with 20 or more staff
Poland
Progress: Partial law in force, remaining obligations in proposal.
Proposal: Yes (16 December 2025, for remaining portions).
Adopted law: Yes, partial (pay range transparency and gender-neutral job titles, 23 June 2025).
Applies from: 24 December 2025 (partial).
Poland split its implementation into stages. Pay range transparency and gender-neutral job titles were enacted on 23 June 2025 and took effect on 24 December 2025. Draft legislation for the remaining Directive obligations was published on 16 December 2025.
What makes Poland notable:
Right to information response deadline tightened to 30 days, compared to 60 days under the Directive
Employers must notify employees by 31 March each year of their right to request pay information
Pay gap reports due by 31 March. If a trade union or equality body requests explanations, employers have only 14 days to respond
Portugal
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Romania
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Slovakia
Progress: Proposal in parliamentary process.
Proposal: Yes (19 September 2025, updated 6 January 2026).
Adopted law: No.
Applies from: Expected 1 June 2026.
Slovakia's draft was formally submitted to the National Council on 6 January 2026 for parliamentary consideration. The government has confirmed the goal is clean, on-time transposition.
What makes Slovakia notable:
Full-scope implementation covering both transparency and reporting requirements, expected to take effect on 1 June 2026
Introduces a 15 April deadline for filing pay gap reports
Provides helpful guidance on grouping employees by the value of their work, applying career progression criteria, and what counts as a legitimate reason for pay differences. The definition of pay is broad, covering bonuses, benefits, and in-kind compensation
Slovenia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour, Family, Social Affairs and Equal Opportunities is working on implementation together with project partners including the Faculty of Economics at the University of Ljubljana and the Diversity Charter of Slovenia.
Spain
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No official announcement yet, but there are indications that a draft is in process.
Sweden
Progress: Proposal published (most detailed in the EU).
Proposal: Yes (May 2024, updated 15 January 2026).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Sweden was the first member state to publish draft legislation in May 2024, delivering the most detailed article-by-article proposal to date. An updated draft titled "Genomförande av lönetransparensdirektivet" was formally referred to the Council on Legislation on 15 January 2026. In April 2025, the Ministry of Labour allocated 10 million SEK for the development of a platform to collect pay reporting data.
What makes Sweden notable:
Two-track reporting system. Employers with 100 or more employees must publish EU Directive-aligned pay gap reports while also continuing Sweden's national pay analyses covering equal work, equal value, and lesser value. Written documentation is required from 25 or more employees
New obligation to analyze pay development following family-related leave
Right to information can be met using existing annual pay analyses. There is no requirement to refresh data outside the annual cycle
The 2026 draft is more complex than the 2024 version. Rather than simplifying, it adds obligations on top of Sweden's existing regime
Austria
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Austria has not publicly signalled any transposition activity. Employers operating in Austria should monitor developments closely, as a compressed timeline is likely once legislative work begins.
Belgium
Progress: Partial transposition (regional).
Proposal: Yes (for FWB region); coming for rest of Belgium.
Adopted law: Yes (Fédération Wallonie-Bruxelles only, 12 September 2024).
Applies from: 2026.
Belgium became the first EU member state to transpose the Directive when the Fédération Wallonie-Bruxelles adopted it in September 2024. However, this only covers approximately 7,500 mostly public-sector employees. On 26 January 2026, the House of Representatives issued a resolution calling on the federal government to implement the Directive across Belgium. The government committed to doing so.
What makes Belgium notable:
First transposition in the EU, but limited to one regional jurisdiction
Pay ranges must be disclosed as soon as job offers or advertisements are published, going further than the Directive requires
Employers must report on the impact of family-related leaves on remuneration, broken down by gender and leave type
Bulgaria
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress. Employers with Bulgarian operations should prepare based on the Directive's baseline requirements.
Croatia
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Cyprus
Progress: Proposal published.
Proposal: Yes (5 November 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Department of Labor Relations published a draft bill in November 2025 covering equal pay through wage transparency and enforcement mechanisms.
What makes Cyprus notable:
Clean transposition that sticks closely to the Directive's baseline without materially tightening thresholds or timelines
Joint pay assessments must specifically examine whether employees returning from parental, maternity, paternity, or carers' leave benefited from pay increases granted in their worker category during their absence
Strong enforcement architecture including fines, criminal liability, and a decisive shift in the burden of proof to employers where transparency obligations are breached
Czechia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour and Social Affairs has indicated that a draft is in process. Czechia has already taken a partial step: the "flexi-amendment" to the Labour Code banned pay secrecy from 1 June 2025.
Denmark
Progress: Proposal published.
Proposal: Yes (26 February 2026).
Adopted law: No.
Applies from: Not yet set (proposal targets 1 January 2027).
Denmark published a draft law amending the Equal Pay Act for consultation on 26 February 2026. The government has openly acknowledged that it will delay implementation beyond the June 2026 deadline, prioritizing administrative alignment and data integrity.
What makes Denmark notable:
Implementation delayed to 1 January 2027, with the first Directive-aligned reports due in September 2028
Employer-friendly approach with no significant "gold plating" beyond what the Directive requires
Statistics Denmark will prepare reports for employers with 150 or more employees using DISCO codes. Employers with 100 to 149 employees will first report in 2031
No requirement to include pay ranges in job postings
Limited reporting for employers with 50 to 99 employees where at least 8 employees of each gender fall within the same 6-digit DISCO group
Finland
Progress: Proposal published.
Proposal: Yes (16 May 2025, updated December 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Finland published a draft in May 2025 addressing pay transparency and reporting. In December 2025, the Ministry of Social Affairs and Health requested formal statements on a government proposal, with comments due by 9 February 2026.
What makes Finland notable:
Three-layer reporting system: the government will calculate overall pay gaps for employers with 100 or more workers using existing payroll data, but employers remain responsible for analyzing results by category of worker. Existing pay audit obligations for companies with 30 or more employees (every two years as part of their Gender Equality Plan) also continue
Pay gap data will be centered on taxable earnings, offering the clearest signal yet of what data will be required
Privacy concerns have been flagged but not resolved. There is no numerical threshold for when pay information should be shared with the works council instead of all employees
Estonia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Head of Gender Equality Policy has indicated that the draft needed to transpose the Directive is being prepared.
France
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The French government launched formal consultations with trade unions and employer federations in May 2025. A draft was scheduled for release in late January 2026.
Germany
Progress: Commission report published, legislative process starting.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Germany formed an 11-person Commission in July 2025 to develop a "bureaucracy-reduced" implementation model. The Commission published its final report on 7 November 2025 and submitted it to the Federal Ministry for Gender Equality. The Ministry will now initiate the formal legislative process. There is no draft law yet.
What makes Germany notable:
Pay gap reporting would be based on actual pay from 2026 payroll data, not targets. The reporting threshold is recommended at 100 employees
Outliers such as severance pay would be excluded, and de minimis exemptions would apply for small in-kind benefits
Right to information is recommended to apply from 2027. Data from comparison groups with fewer than six men and six women would not be shared with employees due to privacy protections
Employers would be required to include a clear description of how each "category of worker" is formed in the right to information report
Greece
Progress: Early stages.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No official announcement yet, but the process to set up a working group has begun.
Hungary
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Ireland
Progress: Partial proposal published.
Proposal: Yes, but only for pay transparency (15 January 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Ireland's draft addresses pre-employment transparency only. Pay gap reporting and other requirements of the Directive are not yet covered.
What makes Ireland notable:
Pay ranges must be included in job advertisements, going beyond the minimum requirement of the Directive
Salary history ban aligned with the Directive
Pay gap reporting, right to information, and other core obligations are still missing from the draft
Italy
Progress: Proposal published.
Proposal: Yes (3 February 2026).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Italy passed Legge n. 15/2024 in February 2024, which mandated the government to issue implementing decrees before the June 2026 deadline. A transposition draft was issued on 3 February 2026.
What makes Italy notable:
"Categories of workers" are primarily defined by collective bargaining classification systems (CCNL) rather than employer-designed job families. Comparability flows from contractual levels negotiated at sector level
Harder at hiring: job applicants must receive detailed pay structure information directly in job advertisements. Easier at scale: employers with 100 or more employees can publish Right to Information data on an intranet or restricted website instead of responding to each request individually
Country-level pay gap reporting is allowed where a unified group pay policy applies, rather than requiring legal-entity-by-entity reporting
Latvia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Welfare has confirmed that Latvia plans to adopt the minimum requirements of the Directive through a new, separate law. Work is underway on both the legal framework and supporting implementation measures.
Luxembourg
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour indicated on 17 November 2025 that a draft bill will be submitted to the Government Council.
Malta
Progress: Partial law in force.
Proposal: Yes (partial).
Adopted law: Yes (partial, 27 June 2025).
Applies from: 27 August 2025 (pay range transparency and right to information only).
Malta passed legislation transposing selective portions of the pay transparency and right to information provisions on 27 June 2025. These took effect on 27 August 2025. The remaining Directive requirements are still pending.
What makes Malta notable:
Earliest effective date in the EU, a full ten months before the deadline, but with narrow scope covering only pre-employment transparency and right to information
Employers can delay disclosing pay ranges and applicable collective agreements until just before the job starts
Right to information is limited to average pay for same work only. There is no right to know pay for "work of equal value" as required by the Directive. Employers have 60 days to respond
Lithuania
Progress: Proposal published.
Proposal: Yes (27 May 2025).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Social Security and Labour presented a full transposition draft to the Tripartite Council on 27 May 2025, covering employer associations, trade unions, and the government.
What makes Lithuania notable:
Extends existing reporting requirements. Lithuania's Social Security institution already publishes monthly average pay gap data. Under the draft, employees can now request job-category-level gap data once a year. If the gap exceeds five percent, employers must explain or fix it
The collective agreement applicable to the position must be provided before discussing or signing the employment contract
Every employer regardless of size must now co-develop formal, gender-neutral pay structures. Previously, this only applied to companies with 20 or more staff
Netherlands
Progress: Proposal published, delayed implementation.
Proposal: Yes (25 March 2025, updated 19 January 2026).
Adopted law: No.
Applies from: Likely 1 January 2027.
The Dutch government issued a draft in March 2025 and sent the wage transparency bill to the Council of State on 19 January 2026. However, the Minister of Social Affairs and Employment has confirmed that the Netherlands is not likely to meet the June 2026 deadline. Entry into force is expected by 1 January 2027.
What makes the Netherlands notable:
Closest to a clean implementation of the Directive among all member states
Employers with 150 or more employees will first report on 2027 pay data, likely in June 2028. Employers with 100 to 149 employees will report in June 2031 on 2030 data
Broad definition of pay. Only employer-wide costs not tracked at the individual level are excluded
Controversial provision: temporary agency workers may be counted in the pay gap data of the host company rather than the staffing agency. This sparked significant criticism during public consultation
Poland
Progress: Partial law in force, remaining obligations in proposal.
Proposal: Yes (16 December 2025, for remaining portions).
Adopted law: Yes, partial (pay range transparency and gender-neutral job titles, 23 June 2025).
Applies from: 24 December 2025 (partial).
Poland split its implementation into stages. Pay range transparency and gender-neutral job titles were enacted on 23 June 2025 and took effect on 24 December 2025. Draft legislation for the remaining Directive obligations was published on 16 December 2025.
What makes Poland notable:
Right to information response deadline tightened to 30 days, compared to 60 days under the Directive
Employers must notify employees by 31 March each year of their right to request pay information
Pay gap reports due by 31 March. If a trade union or equality body requests explanations, employers have only 14 days to respond
Portugal
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Romania
Progress: No public activity.
Proposal: No.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No public signal of transposition progress.
Slovakia
Progress: Proposal in parliamentary process.
Proposal: Yes (19 September 2025, updated 6 January 2026).
Adopted law: No.
Applies from: Expected 1 June 2026.
Slovakia's draft was formally submitted to the National Council on 6 January 2026 for parliamentary consideration. The government has confirmed the goal is clean, on-time transposition.
What makes Slovakia notable:
Full-scope implementation covering both transparency and reporting requirements, expected to take effect on 1 June 2026
Introduces a 15 April deadline for filing pay gap reports
Provides helpful guidance on grouping employees by the value of their work, applying career progression criteria, and what counts as a legitimate reason for pay differences. The definition of pay is broad, covering bonuses, benefits, and in-kind compensation
Slovenia
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
The Ministry of Labour, Family, Social Affairs and Equal Opportunities is working on implementation together with project partners including the Faculty of Economics at the University of Ljubljana and the Diversity Charter of Slovenia.
Sweden
Progress: Proposal published (most detailed in the EU).
Proposal: Yes (May 2024, updated 15 January 2026).
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
Sweden was the first member state to publish draft legislation in May 2024, delivering the most detailed article-by-article proposal to date. An updated draft titled "Genomförande av lönetransparensdirektivet" was formally referred to the Council on Legislation on 15 January 2026. In April 2025, the Ministry of Labour allocated 10 million SEK for the development of a platform to collect pay reporting data.
What makes Sweden notable:
Two-track reporting system. Employers with 100 or more employees must publish EU Directive-aligned pay gap reports while also continuing Sweden's national pay analyses covering equal work, equal value, and lesser value. Written documentation is required from 25 or more employees
New obligation to analyze pay development following family-related leave
Right to information can be met using existing annual pay analyses. There is no requirement to refresh data outside the annual cycle
The 2026 draft is more complex than the 2024 version. Rather than simplifying, it adds obligations on top of Sweden's existing regime
Spain
Progress: Work in progress.
Proposal: No, but coming.
Adopted law: No.
Applies from: Not yet set (must be by 7 June 2026).
No official announcement yet, but there are indications that a draft is in process.
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Product
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Sysarb offers Europe's leading all-in-one platform for Pay Transparency.
Järntorget 12 A
732 30 Arboga
+46 589-501 60
Product
Features
Featured Articles
Sysarb offers Europe's leading all-in-one platform for Pay Transparency.
Järntorget 12 A
732 30 Arboga
+46 589-501 60
Product
Features
Featured Articles
Sysarb offers Europe's leading all-in-one platform for Pay Transparency.
Järntorget 12 A
732 30 Arboga
+46 589-501 60
Product
Features
Featured Articles