EU Pay Transparency Directive Transposition Activity by Nation

As of our most recent update, there is no known transposition activity in Austria. However, the country has current legislation in effect. The existing legislation requires employers with over 150 employees to provide employees with a pay report.

TBC

As of our most recent update, there is no known transposition activity at the national level in Belgium. However, two of the nation's regions have published drafts that partially transpose the Directive.

• 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 Bulgaria.

TBC

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

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

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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.

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As of our most recent update, there is no known transposition activity in Denmark. However, the country has current legislation in effect. The existing legislation, dating from 2006, requires employers with 35 or more employees to provide employees with a pay report.

TBC

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. Check out the timeline published by the Ministry of Economic Affairs and Communications for more information.

TBC

On May 16th, 2025, Finland’s Ministry of Social Affairs and Health working group published its draft legislation to transpose the EU Directive. The legislation will be reviewed by the Finnish parliament in autumn of 2025 and the official government proposal is now expected to be published in December 2025. 

The draft legislation would enact a full transposition of the EU Directive by amending Finland’s existing Act on Equality Between Women and Men. The government holds that this legislation is at the minimum level required by the Directive; however, a few employer groups disagree.

No

May 18th, 2026

See our full article for a few nuances of the draft legislation.

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 resources page.

In October 2025, a German government committee issued a report that provides guidance on EU Directive transposition. Based on the recommendations, Germany’s new pay transparency and equity requirements would stay fairly close to the Directive’s set thresholds. The committee also recommends digital tools, like reporting portals and pay gap analysis tools, to ease the administrative burden on employers. Pay equity experts speculate 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.

TBC

For more information, check out our article on Germany's pay transparency and pay equity law and reporting.

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

TBC

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

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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.

In 2024, Italy passed Law no. 15/2024, which laid the legal foundation for transposition and set a 2026 deadline. However, specific legislation has yet to emerge.

Italy already has 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.

TBC

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

TBC

On May 20th, 2025, Lithuania published draft legislation that would partially transpose the EU Directive. This legislation builds on the existing framework of Lithuania’s Labour Code and Administrative Code.

The pre-existing legislation includes 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 pay transparency, employers must provide salary range information for open jobs and cannot ask applicants or employees about salary history.

The draft legislation expands existing law and transposes many elements of the EU Directive. It includes the Directive’s pay transparency provisions that guarantee employees’ right to information, and it requires employers to have formal pay systems based on objective, gender-neutral criteria. Two of the Directive’s requirements (reporting and joint assessment) will need to be addressed separately.

TBC

See our full discussion of Lithuania’s draft legislation.

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

TBC

Malta has taken initial steps towards transposing the EU Directive with a Legal Notice that was published by the Maltese parliament on June 27th, 2025 and took effect on August 27th, 2025.

The Legal Notice gives employees the right to request a written assessment between their pay level and the categories of workers performing the same work. (Note that this does not address the comparison to “work of equal value,” as required under the EU Directive.) The Legal Notice also entitles job-seekers to receive written information about the pay range, along with any relevant collective agreements, prior to starting employment.

August 27th, 2025

For all the details of the partial transposition in Malta, read our full article.

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.

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 (see above, “The EU Pay Transparency Directive in a nutshell.”). 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. On September 24th, 2025, the government announced a 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. 

January 1st, 2027

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

In June 2025, the Polish parliament amended its existing Labor Code to partially transpose the EU Directive. These changes are connected to pay transparency: they require non-discriminatory recruitment processes, mandate that job candidates be informed of pay ranges prior to employment, and prohibit employers from asking about salary history. These changes came into effect on December 23rd, 2025.

Additionally, on December 16th, 2025, a draft act was introduced that would fill the gap and fully meet the Directive’s requirements. This addresses the pay equity elements of the Directive including employees’ right to information and pay gap reporting requirements. This draft legislation is anticipated to take effect on the Directive deadline of June 7th, 2026.

December 23rd, 2025, for pay transparency provisions, and June 7th, 2026, for full transposition.

Deep dive into Poland's implementation details in our article.

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.

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Learn more about local requirements in Portugal in this article.

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.

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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 Slovenia.

TBC

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.

Legislation was drafted in Sweden as of May 2024. The draft legislation adds the EU Directive’s requirement to Sweden’s own existing legislation. As of December 2025, the Swedish government has stated that it is on track to finalize its legislation in January 2026.

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.

TBC

For more information about lönekartläggning, visit our local requirements page for Sweden.