Last updated 2025-08-22
Quick overview
Estonia is preparing to implement new gender pay transparency and reporting rules as required by the EU Pay Transparency Directive (EUPTD). Although Estonia has not yet published draft legislation as of July 2025, all EU Member States must adopt and apply these rules by June 7, 2026.
For HR leaders and Compensation & Benefits professionals, these changes will mean new reporting obligations, stricter transparency requirements in hiring and pay practices, and higher scrutiny around equal pay compliance.
Reporting requirements
Which companies must report?
Currently, Estonia does not require private employers to publish or submit gender pay gap reports. This will change starting in 2026 under the EUPTD.
What information needs to be reported?
At present, there is no mandatory disclosure of gender pay data to employees, regulators, or the public.
When and where to send the data?
There is no official reporting platform in use today. Estonia is expected to create a national platform — likely managed by the labor ministry or an equality authority — when the EU rules take effect.
Who can see the results?
No public or employee-level pay gap data is currently available because reporting is not mandatory.
Equal pay laws
Under the Estonian Labor Act, employers are prohibited from discriminating against employees based on gender. The law requires equal pay for equal work, meaning men and women performing the same job or work of equal value must receive the same pay.
However, these protections lack structured mechanisms for measuring and addressing pay gaps. There are no obligations for companies to analyze, report, or correct potential inequities unless an individual discrimination claim is raised.
Employee rights
Employees in Estonia have the right to:
Equal treatment and equal pay for equal work
Protection against retaliation when raising discrimination concerns
Filing complaints with the Labor Inspectorate or through the courts in cases of pay discrimination
That said, without mandated transparency, employees have limited access to data to support such claims.
Risks of non-compliance
At present, risks are limited to potential legal claims for discrimination under the Labor Act. These cases typically require employees to provide proof, which can be challenging without access to pay data.
No administrative penalties or mandatory corrective actions exist today for pay gap non-reporting, because reporting obligations have not yet been introduced.
What will change by 2026
New EU-wide rules
The EUPTD introduces significant new obligations for employers in Estonia:
Reporting thresholds
250+ employees: Annual reporting starting in 2027 for 2026 data
150–249 employees: Triennial reporting starting in 2027
100–149 employees: Triennial reporting starting in 2031
Fewer than 100 employees: No mandatory reporting
Reporting content
Mean and median gender pay gaps for total pay and variable components
Proportion of male and female employees receiving bonuses
Gender distribution across pay quartiles
Pay gaps by job category, broken down by fixed and variable pay
Joint Pay Assessments
Required if a 5% or greater unexplained gap persists in a job category for six months
Recruitment transparency
Disclosure of pay ranges in job postings or before interviews
Prohibition on asking for salary history
Requirement to use gender-neutral job descriptions
How Estonia is likely to apply them
Estonia is expected to transpose the directive in full, with implementation and oversight likely assigned to:
The Labor Inspectorate
The Office for Gender Equality
Employers will need to prepare for annual or triennial filings, internal disclosures to employees, and potential public publication of aggregated pay gap data.
FAQ
Will small companies be affected?
Firms with fewer than 100 employees will not face mandatory reporting, but they must still comply with equal pay rules and may be subject to transparency obligations in recruitment.
What if a pay gap is found?
Companies with unexplained gaps of 5% or more in specific job categories will need to perform a Joint Pay Assessment with employee representatives.
Will employees gain more access to data?
Yes. Employees will be entitled to request information on pay levels and differences for comparable roles, and employers will be required to share explanations and corrective measures.
What are the penalties for non-compliance?
Administrative fines and a reversal of the burden of proof in discrimination cases will apply. Employees will also have enhanced rights to compensation.
Helpful resources
EU Pay Transparency Directive overview
Estonian Labor Act (current equal pay provisions)
EU transposition monitor for pay transparency developments
