EU Pay Transparency Directive Transposition Activity by Nation

Austria

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

However, the country does have current legislation in effect. The existing legislation requires employers with over 150 employees to provide employees with a pay report.

Belgium 

In September 2024, the French Community of Belgium, 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.

Their requirements are:

• Annual pay audit requirement for all employers
• For those with 50-99 employees, a simplified short form wage structure analysis every two years
• For those with 100 or more employees, a complete wage structure analysis every two years
• Action plan if the analysis reveals any inequalities
• Mediation for any specific instances of pay inequality

We go into this transposition activity in more depth in this article.

This transposition into law is only partial, as the French Community of Belgium is waiting for the law to be transposed at the national level.

As of our most recent update, there is no known transposition activity at the national level in Belgium.

However, the country does have current legislation in effect. The required annual audit, which companies send to the National Bank, needs to 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.

Bulgaria

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

Croatia

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

Cyprus

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

Czech Republic

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.

Denmark

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

However, the country does have current legislation in effect. The existing legislation, dating from 2006, requires employers with 35 or more employees to provide employees with a pay report.

Estonia

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. (See the timeline published by the Ministry of Economic Affairs and Communications.)

Finland

While there is no transposition activity in Finland just yet, the Ministry of Social Affairs and Health has set up a working group to implement the EU Pay Transparency Directive. 

Finland already has pre-existing pay legislation that requires employers with 30 or more employees to submit a gender equality plan, which includes a pay survey.

France

There is no official transposition activity in France, as of our most recent update. 

However, the country does have current legislation in effect. Since the 2018 introduction of the gender equality index, employers with over 50 employees must submit an annual pay gap report. See our local resources page for more detail on meeting the pay equity reporting requirements in France.

Germany

Government officials have announced that Germany is planning to transpose the EU Directive by the end of the 2024 legislative session. Pay equity experts speculate, however, that reporting will not be required until 2027. 

Germany already has pay transparency legislation in place: the 2017 Transparency in Wage Structures Act (Entgelttransparenzgesetz) requires all organizations with over 200 employees to be ready to provide pay structure information to employees on request, including information about how that individual’s pay is determined. Employers with over 500 employees are required to report on gender equality and equal pay every few years.

Greece

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

Hungary

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

Ireland

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

However, Ireland already has existing pay equity reporting requirements—see our local resources page for more detail. As of 2024, organizations with over 150 employees are required to report annually, and this will expand to all organizations with over 50 employees as of 2025. 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 legislation to make it Directive-compliant.

Italy

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

Italy does already have existing reporting requirements dating back to 2021, which requires employers with 50 or more employees to report on gender and pay data every two years.

Latvia

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

Lithuania

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

However, the country does have existing pay equity and pay transparency legislation. In terms of pay equity, there is a gender pay gap reporting requirement for employers with 20 or more workers, and if the gap exceeds 5%, the organization is required to take action to close it. In terms of transparency, employers must provide salary range information for open jobs and cannot ask applicants or employees about salary history. There are also provisions concerning employment and advancement opportunities for workers with disabilities.

Luxembourg

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

Malta

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

Netherlands

There are no current gender pay gap reporting obligations. However, since 2019, the Netherlands has been debating a bill that would require employers to provide employee salary data every three years, require those with 250 or more employees to get certified as paying fairly, and make pay data available to employees on request.

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.

Poland

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

Portugal

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

However, Portugal does have 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. We’ve also written in more depth about the local requirements for Portugal.

Romania

As of our most recent update, there is no known transposition activity in Romania. Under current Romanian law, employees’ salaries are confidential, so moving to transparency under the EU Directive will be a large shift for employers.

Slovakia

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

Slovenia

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

Spain

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

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

Sweden

Legislation was drafted in Sweden as of May 2024. The draft legislation adds the EU Directive’s requirement to Sweden’s own existing legislation. 

Sweden’s current requirements focus on a compensation mapping analysis called lönekartläggning that all employers must complete annually. Employers of a certain size who identify a pay gap must enact, document, and follow up on a plan for remediation. We talk in more depth about lönekartläggning on our local requirements page for Sweden.