EU Pay Transparency Directive Transposition Tracker

3 things to know about the Belgium Law: EU Pay Transparency Directive

• First transposition but regionally limited: First to fully transpose the Directive but only covers approx 7,500 mostly public sector employees subject to jurisdiction of Fédération Wallonie-Bruxelles.
• Strict pay range transparency: Goes farther than the Directive pay ranges must be shared as soon as job offers or ads are published.
• Pay reporting beyond the Directive’s baseline: Mandates reporting on the impact of family-related leaves on remuneration, disaggregated by gender and leave type.

3 things to know about the Finland Draft: EU Pay Transparency Directive

• Reporting nuances, galore. Finland’s draft takes a layered approach: the government will calculate overall pay gaps for employers with 100+ workers using existing payroll data submitted to authorities, but employers are still responsible for analysing results down by category of worker. Meanwhile, existing rules remain: companies with 30+ employees must continue conducting a pay audit every two years as part of their Gender Equality Plan. Bottom line: three schemes, layered obligations, and more work for employers.
• Focus on taxable earnings: Because the government’s report is based on existing payroll submissions, Finland offers the clearest signal yet of what data will be required, and it’s centered on taxable earnings.
• Privacy flagged, but not solved. The draft acknowledges privacy concerns but stops short of clarity: there’s no numerical threshold for when information should be shared only with the works council instead of all employees.

3 things to know about the German Commission’s Report: EU Pay Transparency Directive

• Bureaucracy-light, detail-heavy. There is no draft law yet, but Germany is one step closer. A German Commission has issued its report outlining a “bureaucracy-reduced” model to guide lawmakers in drafting the Directive’s implementation, with a formal bill expected in early 2026. The report is not binding, but it is anything but shallow. It dives into definitions, data categories, and reporting mechanics. For employers, it’s the most comprehensive look yet at how Germany could operationalize the Directive’s right to information and pay gap reporting without drowning companies in red tape.
• Actual pay, pragmatic pay gap reporting. The Commission takes a firmly practical stance: pay gap reporting under Article 9 should be based on actual pay (2026 payroll data), not targets, calculated from the sum of all remuneration components but excluding outliers such as severance pay and allowing de minimis exemptions for small in-kind benefits. It recommends setting the reporting threshold at 100 employees, no lower. Together, these choices point to a manageable, employer-friendly compliance model.

• Right to information is delayed, but defined. The Commission recommends that the right to information under Germany’s future law apply for the first time in 2027 (either by 7 June 2027 or, according to some members, on 1 January 2027) while maintaining the existing law through 2026. Requests would be based on an annual snapshot, can be delivered digitally, and data from small comparison groups (fewer than six men and six women) would not be shared with employees due to privacy protections. One recommended addition from the Commission: include a clear description of how each “category of worker” is formed in the right to information report.

3 things to know about the Ireland Draft: EU Pay Transparency Directive

• Partial picture, gaps to fill: Ireland’s draft focuses on pre-employment transparency but omits rest, including pay gap reporting.
• Pay ranges in job posting: The draft requires pay ranges to be included in job advertisements, going beyond what is minimally required by the Directive.
• Alignment on salary history ban: Bans asking about prior pay, aligned with the EU Pay Transparency Directive

3 things to know about the Lithuania Draft: EU Pay Transparency Directive

• Extends existing reporting requirements: Lithuania’s Social Security institution already publishes monthly average pay gap data. Under the draft, employees or their representatives can now request job category level gap data once a year (if there are at least two employees in that role). If the gap exceeds five percent, employers must explain or fix it.
• Pay scale transparency is not new: Pay scale transparency is already the law in Lithuania. However, now the draft makes clear that the collective agreement applicable to the position must also be provided before discussing or signing the employment contract, in line with the requirements of the EU Pay Transparency Directive.
• Formal pay systems, with no more size exemption: Lithuania already required companies with 20 or more staff to co-develop formal and gender neutral pay structures. Now every employer, regardless of size, must do the same. Small firms are no longer off the hook.

3 things to know about the Malta Law: EU Pay Transparency Directive

• Early start, but narrow scope: Malta’s partial draft takes effect on 27 August 2025, a full ten months before the EU deadline. But it only covers pre employment transparency for now. The rest of the Directive is still in waiting.
• Pay scale can wait: Unlike some countries pushing for upfront clarity, Malta allows employers to delay disclosing pay ranges and applicable collective agreements until just before the job starts. Applicants could accept offers with limited visibility into pay structure.
• Limited right to information: Employees can request pay data, but only for average pay of others doing the same work. There is no right to know pay for work of equal value, as required by the Directive. Employers still have have sixty days to respond.

3 things to know about The Netherlands Draft: EU Pay Transparency Directive

• Stays truest to the Directive but implementation likely delayed: The Netherlands has proposed a draft of both pay transparency and pay reporting requirements that is the closest to a clean implementation of the EU Pay Transparency Directive we’ve seen so far. The NEW! catch: the implementation deadline is slipping. The Dutch legislation will likely not go into effect until 1 January 2027. For gender pay gap reporting, this means that employers with 150+ employees will first report on 2027 pay data (not 2026), likely in June 2028. Employers with 100–149 employees will stick to the Directive’s original timeline: reporting in June 2031 on 2030 data. The transparency obligations are expected to apply starting 1 January 2027.
• Pay is broad and more guidance is coming: Takes a broad definition of pay that will be included in pay gap reporting and right to information. Only employer-wide costs not tracked at the individual level are excluded, keeping reports standardized and comparable. More definition of wages coming soon.
• Temporary workers may be included in pay gap reports for the “host” company: Under the draft, temporary agency workers made available under the Allocation of Workers by Intermediaries Act should be counted in the pay data of the company they’re working for, not the staffing agency that employs them. Will it survive? This approach sparked significant criticism in the public comments. The core concern: companies argued they don’t set the wages for these workers, so holding them accountable for the agency’s pay decisions could distort results and create liability without control.

3 things to know about the Poland Law: EU Pay Transparency Directive

• Piecemeal approach and accelerated timeline: Only addresses the pay range transparency and gender neutral job title obligations; Poland plans for a second process for rest. These pay requirements will take effect 24 December 2025, 6 months after the law was signed by the Polish President and published in the official journal.
• Steps back from more aggressive right to information timeline: Steps back from earlier draft, which shortened right to information timeline to 14 days. Right to information was not included in this
• Does not require posting job ranges in job advertisement: Can provide in the job advertisement, before the interview, or before entering into an employment relationship. Must be in writing (paper or electronic).

3 things to know about the Slovak Draft: EU Pay Transparency Directive

• Full scope implementation, on time: Slovakia’s draft covers both transparency and reporting requirements and is expected to take effect on 1 June 2026. The government confirms that the goal is clean transposition. There are no lowered thresholds, no enhanced requirements, and no new pay gap reporting requirements. While there is no gold plating, there is helpful operational guidance and a few tweaks.
• Pay gap reporting cycle changes, but not right away: One tweak is a change to future pay gap reporting deadlines. The draft introduces a 31 March deadline for filing pay gap reports. The good news is that the first deadlines remain fully aligned with the Directive. Employers with 150 or more employees must report by 7 June 2027, and those with 100 to 149 employees by 7 June 2031. The 31 March deadline will not kick in until later.
• Somewhat more guidance on job categories and pay criteria: While there is nothing earthshattering, the draft provides some helpful guidance on how to group employees by the value of their work, how to apply career progression criteria, and what counts as a legitimate reason for pay differences. The definition of pay is broad, covering bonuses, benefits, and in-kind compensation, just as required under the Directive.