Last updated 2025-08-22
Quick overview
Malta has formally begun its path toward pay transparency reform. On June 27, 2025, the government published Legal Notice 112 of 2025. The provisions take effect on August 27, 2025 and introduce the country’s first binding pay transparency measures.
These measures focus on salary range disclosure during recruitment and employees’ rights to request pay information. Malta has not yet introduced full gender pay gap reporting at the organizational level, but is expected to do so in stages as required by the EU Pay Transparency Directive (EUPTD) by June 7, 2026.
For HR and Comp & Ben leaders, this means preparing both for immediate compliance obligations in 2025 and for expanded reporting duties that will apply from 2027 onward.
Reporting requirements
Which companies must report?
At present, no Maltese employers are required to publish organizational-level gender pay gap reports.
Legal Notice 112 of 2025 focuses on:
Pre-employment pay transparency
Employee rights to request pay data
Future reporting requirements under the EUPTD will be phased in from 2027, beginning with large employers.
What information needs to be reported?
Currently, the obligations are limited to:
Disclosing the starting salary or salary range for job vacancies before employment begins
Providing employees with their individual gross annual or hourly pay on request
Sharing pay information for workers performing the same work
The right to comparison is narrower than the EU Directive, as it does not yet extend to “work of equal value.”
When and where to send the data?
Malta has not yet established a reporting platform or designated a national authority to collect pay gap reports. These details are expected in future legislation transposing the Directive.
Employers should expect requirements to align with EU rules, meaning submission to a national body, publication on an official platform, and sharing internally with employees and worker representatives.
Who can see the results?
At this stage, only employees who request pay information are entitled to see it, and only in relation to “same work.”
Equal pay laws
Article 27 of the Employment and Industrial Relations Act guarantees equal pay for equal work. Legal Notice 112 of 2025 builds on this framework by introducing actionable transparency measures such as pre-employment salary range disclosures and the right to pay information.
Employee rights
Effective August 27, 2025, employees in Malta gain the following rights:
To request their individual gross pay (annual or hourly)
To request pay information for workers performing the same work
To receive a response within two months of submitting the request
Job applicants also gain the right to be informed of the starting salary or pay range before signing an employment contract.
Risks of non-compliance
Legal Notice 112 introduces obligations, but enforcement mechanisms and penalties remain to be detailed in upcoming legislation. Based on the Directive and EU practice, risks will likely include:
Administrative fines for failure to disclose pay ranges or respond to employee requests
Litigation and reputational risk if employers are found to conceal or withhold pay information
Public scrutiny once Malta establishes pay reporting platforms
What will change by 2026
New EU-wide rules
Under the EU Pay Transparency Directive, all Member States must:
Require employers to publish salary ranges in job postings
Guarantee employee rights to pay transparency
Mandate organizational-level gender pay gap reporting based on workforce size
Introduce Joint Pay Assessments when unjustified pay gaps of at least 5% are identified
Establish sanctions, remedies, and a shift in the burden of proof for discrimination cases
How Malta is likely to apply them
Malta has already taken a first step through Legal Notice 112, which focuses on pre-employment and employee-level transparency.
Next, Malta is expected to:
Introduce gender-neutral pay systems
Expand comparison rights from “same work” to “same or work of equal value”
Establish a national authority and reporting platform
Phase in reporting obligations:
250+ employees: Annual reporting starting in 2027
150–249 employees: Every three years from 2027
100–149 employees: Every three years from 2031
Below 100 employees: Exempt, unless thresholds are lowered
FAQ
Does Malta already require gender pay gap reports?
Not yet. Current obligations are limited to salary range disclosures and employee rights to pay information.
When will reporting start?
The first reporting obligations are expected in 2027, covering data from 2026, in line with the EUPTD.
Which employees can request pay data?
Any employee can request their own pay and that of workers performing the same work.
How fast must employers respond?
Employers must respond within two months.
Helpful resources
Employment and Industrial Relations Act, Article 27
Legal Notice 112 of 2025 (Pay Transparency Measures)
European Commission – Pay Transparency Directive (Directive (EU) 2023/970)
Sysarb EU Pay Transparency Monitor for tracking implementation across Member States
