EU Pay Transparency Directive Transposition Activity by Nation

A motion for a resolution was submitted to the Belgian Chamber of Representatives on January 2026, regarding the implementation of the European Union Directive on pay transparency (Directive (EU) 2023/970).
Main points in the proposal:

• Avoid "gold-plating": Not create new legislation that goes beyond the strict requirements of the EU Directive.
• Legislative adjustments: Limit actions in the private sector to minor textual changes to existing social laws while extending pay transparency to all federal public employment following the example of the Flemish draft.
• Screen administrative burdens: Propose a thorough screening of increasing administrative burdens at the informal European summit on February 12, 2026, to protect business competitiveness.

French Community of Belgium

In September 2024, this region, also known as the Wallonia-Brussels Federation or Fédération Wallonie-Bruxelles, became the first EU jurisdiction to transpose the EU Pay Transparency Directive into law.

Flanders

In late 2025, the Flemish government published a draft decree partially transposing the Directive for the public sector.

Additionally, Belgium has other pay equity and transparency legislation in effect. The required annual audit, which companies are required to send to the National Bank, must include the pay difference between men and women. Companies with 50 or more employees also need to submit a more detailed pay structure analysis every two years.

January 1st, 2025

We go into Belgium's transposition activity in more depth in this article, including updates on the French Community.

For updates on the Flemish Region, see this article.

As of our most recent update, there is no known transposition activity in Croatia.

TBC

Although there has been no official announcement of transposition activity in the Czech Republic, a government working group has been set up and legislation is being drafted by the Ministry of Labor and Social Affairs.

TBC

More details on Czech Republic's pay transparency legislation changes.

As of our most recent update, there is no known transposition activity in Estonia. The government is currently developing a digital solution, called Palagapeegel or Pay Mirror, that employers will use for their reporting activity when the transposed legislation takes effect in 2026.

TBC

Current legislation in France dates to 2018 and is based on the nation’s gender equality index. The law mandates that employers with over 50 employees must submit an annual pay gap report.

Since May 2025, the nation’s government has been working to develop a new index to replace its current system. This new index will be based on the metrics set out in the EU Directive and will incorporate the Directive’s key requirements. This includes the pay transparency mandates, rules for pay assessments if an employer’s gender pay gap is over 5%, and fines for noncompliance.

The planned legislation exceeds the Directive’s minimum requirements in one area. While the Directive states that employers with 100 or more employees must report their pay gap metrics, France plans to keep its current reporting threshold of 50 employees. This new legislation is planned to take effect on the Directive’s transposition deadline of June 7th, 2026.

June 7th, 2026

For more detail on the current pay equity reporting requirements in France, see our local requirements page.

As of our most recent update, Greece has begun developing a working group to transpose the Directive.

TBC

On January 15th, 2025, Ireland published draft legislation that would partially transpose the EU Directive, specifically with regard to its pay transparency provisions. The first provision of this legislation would require a remuneration rate or range in all job postings. The second would prohibit employers from asking applicants about their pay history. There is no official information about when this draft legislation will be considered. 

The draft legislation does not address pay gap reporting requirements. Ireland does already have legislation in this area. 

As of June 1st, 2025, all organizations with over 50 employees are required to report. The current reporting requirement specifies that employers must report gender pay gaps (mean and median), statistics on benefits in kind and bonuses, and gender distribution in each salary quartile. Since the EU Directive lays out more specific and detailed reporting requirements, Ireland is expected to change its reporting legislation to make it Directive-compliant.

TBC

For more information on Ireland's transposition activity, see our in-depth article.

As of our most recent update, there is no known transposition activity in Latvia.

TBC

As of our most recent update, there is no known transposition activity in Luxembourg.

TBC

On January 2026, the Dutch government sent and updated, revised draft to the Council of State, following its announced delay in the Directive's implementation, setting January 1st, 2027, as the new transposition deadline rather than June 2026. The first required pay gap reports would then be based on 2027 data.

In late March 2025, draft legislation was introduced that would fully transpose the EU Directive. In regard to pay transparency, this legislation would enact all the directive’s basic requirements. It further specifies that employees must have “easy access” to the criteria used to determine wages and pay levels, and it sets a limit of two months for employers to respond to an employee’s request for a personalized pay comparison.

In terms of pay gap reporting, the draft legislation would require the specific metrics stipulated in the Directive (see our quick guide for a listing of those metrics.) This legislation would also establish an administrative body to collect and review the required pay gap reporting data, develop tools to help assess gaps, and hear and act on complaints about employer noncompliance. However, the collapse of the Dutch coalition government in summer 2025 has delayed consideration and implementation of this legislation.

There are no current gender pay gap reporting obligations. Currently, companies with 100 or more employees must have an annual discussion with their works council. This discussion covers changes in pay ratios since the previous year.

January 1st, 2027

More information on the Directive's transposition activity in the Netherlands.

As of our most recent update, there is no known transposition activity in Portugal.

However, Portugal has current requirements in place. Employers need to have transparent pay policies that include an objective approach to evaluating job functions. They also need to report pay data to the government, which checks it for gender-based pay gaps. The key legislation currently in effect is Law 60/2018, which was implemented in 2019.

TBC

Learn more about local requirements in Portugal in this article.

On September 19th, 2025, Slovakia’s government introduced draft legislation that would fully transpose the EU Directive. To do so, the draft legislation would enact a new pay transparency law and would amend parts of the existing Labor Code, Labor Inspection Act, and Employment Services Act. The draft mirrors the EU Directive’s requirements, imposing them at the minimum level stipulated. 

Slovakia’s draft legislation was open for comment until October 9th, 2025, and is expected to be approved soon. The effective date for the new law would be June 1st, 2026, with the first reporting requirements scheduled for 2027.

June 1st, 2026

For more information on Slovakia's transposition, see our full article.

As of our most recent update, there is no known transposition activity in Spain. The country has some foundational pay equity legislation that was passed in 2021, although the EU Directive will go beyond those requirements. The existing requirements include an annual remuneration register, an auditing requirement and job evaluation requirement for organizations with 50 or more workers, and employees’ right to pay information.

TBC

Our local requirements page provides more information about Spain’s current legislation.