This tracker provides a status roundup of each EU member state's progress transposing the EU Pay Transparency Directive into national law.
The EU Pay Transparency Directive requires companies to report pay gaps between female and male workers and promote pay structures reflecting “equal pay for equal work or work of equal value”.
The new directive places the onus on employers to disclose pay information, justify disparities and ensure pay equity. It applies to all companies with at least 100 employees.
Adopted in May 2023, the directive responds to persistent challenges implementing the right to equal pay under previous EU legislation. Women still earn, on average, 13% less than men, according to the European Council.
What measures are in the directive?
- introduce stricter pay reporting requirements and pay evaluations;
- introduce pay disclosure requirements before the job interview stage;
- ban salary non-disclosure agreements and asking candidates about their pay history;
- expand employee rights to information on average pay levels and increased transparency on pay setting and progression;
- impose stronger enforcement mechanisms, including fines for non-compliance and compensation to victims of pay discrimination.
EU member states must transpose the directive into national law by 7 June 2026.
Transposition so far is patchy. Some countries like Belgium, Ireland, the Netherlands, Poland and Sweden have already published draft legislation, but others are yet to announce formal steps. Some already have existing laws in place that align at least in part with the directive’s measures.
| Member state | Implementation status |
| Austria | Not yet implemented |
| Belgium | Partial implementation |
| Bulgaria | Not yet implemented |
| Croatia | Not yet implemented |
| Cyprus | Not yet implemented |
| Czechia | Draft legislation proposed |
| Denmark | Not yet implemented |
| Estonia | Not yet implemented |
| Finland | Draft legislation proposed |
| France | Draft legislation proposed |
| Germany | Not yet implemented |
| Greece | Not yet implemented |
| Hungary | Not yet implemented |
| Ireland | Draft legislation proposed |
| Italy | Not yet implemented |
| Latvia | Not yet implemented |
| Lithuania | Draft legislation proposed |
| Luxembourg | Not yet implemented |
| Malta | Partial implementation |
| Netherlands | Draft legislation proposed |
| Poland | Draft legislation proposed |
| Portugal | Not yet implemented |
| Romania | Not yet implemented |
| Slovakia | Draft legislation proposed |
| Slovenia | Not yet implemented |
| Spain | Not yet implemented |
| Sweden | Draft legislation proposed |
Austria
Austria has no current proposal to transpose the directive.
However, Austria does have existing mechanisms promoting equal pay and pay transparency. They require employers to state the minimum salary in job adverts and impose pay reporting obligations on businesses with more than 150 employees under the Equal Treatment Act 2004. Austria will still be required to transpose the significant requirements from the directive into national law.
Relevant legislation
Related commentary
Belgium
Belgium’s Fédération Wallonie-Bruxelles became the first to transpose the directive into domestic law, effective from 1 January 2025. It only applies to public sector employers in the French Community of Belgium.
The Fédération’s decree (French language only) goes beyond the basic requirements in the directive by mandating employers to disclose starting salaries or salary ranges in job postings. Employers must also use non-discriminatory job titles and assess the impact of family-related leave on remuneration as part of gender pay reporting obligations.
The directive still needs to be transposed nationally across Belgium. Pay reporting obligations already exist nationwide for companies with more than 50 employees under the Gender Pay Law 2012 (French language only).
Relevant legislation
- Decree amending the Decree of 12 December 2008 (French language only)
- Gender Pay Law 2012 (French language only)
Related commentary
Cyprus
On 11 June 2025, the Ministry of Labour and Social Insurance confirmed its support for implementing the directive by launching the "eValueJobs" project. The initiative, co-funded by the EU, focuses on developing digital tools for gender-neutral job evaluation, training employers and social partners, and promoting transparent pay structures. The Ministry established focus groups to promote the principle of equal pay between men and women.
As of January 2025, it became obligatory for all employers to sign up by 31 May 2025 to the ERGANI (Greek language only) information system, a digital platform that collects detailed employment data such as job titles, salaries, and working hours. ERGANI is being adapted to support the directive’s requirements by enabling the monitoring of gender pay gaps and ensuring transparency in pay-setting practices.
Relevant legislation
- Implementing the eValues project (Greek language only)
Related commentary
Czechia
The Ministry of Labour and Social Affairs confirmed in April 2023 (Czech language only) that the directive will enter national legislation through amendments to the Labour Code 2006, alongside measures from the government's Action Plan for Equal Pay for Women and Men 2023-2026 (Czech language only). The government has also set up a working group to support the transposition.
New amendments to the Labour Code, which came into effect on 1 June 2025, include a ban on pay secrecy clauses, bringing Czech legislation into partial alignment with the directive's provisions. Companies may be fined up to CZK400,000 (US$18987.94) if they continue to include them in employment contracts.
Relevant legislation
- Labour Code 2006
- Action Plan for Equal Pay for Women and Men 2023-2026 (Czech language only)
Related commentary
Denmark
Denmark has no current proposal to transpose the directive.
Existing legislation already requires employers with 35 or more employees to provide a gender-specific pay report, under the Equal Pay for Women and Men Act 2006.
Relevant legislation
Estonia
Estonia is taking active steps towards supporting pay transparency; however, no draft legislation has been put forward yet.
The government is developing a digital platform called Pay Mirror (Palgapeegel) to help employers analyse pay gaps in their organisation. It is also preparing employer guidance for job evaluations.
Relevant legislation
Finland
On 16 May 2025, Finland published a draft proposal (Finnish or Swedish language only) implementing the directive through amendments to the Act On Equality Between Women and Men 1986. The Act already requires employers with more than 30 employees to prepare a gender equality plan and justify unexplained pay gaps between men and women.
The draft proposal aligns with the directive's minimum requirements. It requires companies with 100 or more employees to report gender pay gaps; mandates gender-neutral job adverts; requires pay range disclosure prior to salary negotiations; prohibits employers from requesting information about job applicants' pay history; and includes penalties for non-compliance.
The bill is under consultation and is scheduled to reach parliament in autumn 2025, with the final legislation proposed to take effect on 18 May 2026.
Relevant legislation
- Proposal on the implementation of the Pay Transparency Directive progresses
- Act On Equality Between Women and Men 1986
Related commentary
France
On 21 May 2025, the Minister of Labour launched a formal consultation on transposing the directive into French law. The government planned to vote on the draft legislation in autumn 2025, but the dissolution of the government in September has slowed down the process.
The ministry is reviewing France’s Gender Equality Index 2018, which currently requires employers with over 50 employees to submit an annual pay gap report, a threshold that exceeds the directive’s obligation. It will be replaced with a new index closely aligned with the directive’s requirements, with some indicators automatically reported on a digital system (Declaration Sociale Nominative). Companies will have to justify any unexplained pay gaps exceeding 5%, with potential penalties for non-compliance.
Relevant legislation
Related commentary
Germany
On 17 July 2025, the coalition government appointed an 11-person commission to develop proposals for the implementation of the directive. These will be submitted to the Federal Ministry for Gender Equality by the end of October 2025.
Germany already has some pay transparency legislation in place, prohibiting businesses from discriminating against employees when determining pay. The Transparency in Wage Structures Act 2017 allows workers at companies with more than 200 employees to request salary information for their role and comparable positions. Employers with over 500 employees already have to report on their gender equality measures every three to five years.
Relevant legislation
Related commentary
Greece
Greece has taken preliminary steps to align with the directive but has yet to formally introduce legislation to transpose it into national law.
In March 2025, the Ministry of Family and Social Cohesion set up the Fair Pay project (Greek language only), funded by the European Commission, which takes into account the requirements of the EU directive.
The initiative aims to develop tools and methodologies for gender-neutral job evaluation and to support employers in implementing transparent pay structures and to raise awareness on equal pay principles.
Related commentary
- FAIR PAY to promote pay transparency and pay equality between men and women (Greek language only)
Ireland
Ireland became the fourth European country to initiate the directive in its General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 on 15 January 2025. It includes two key measures for pay transparency: first, employers must disclose salary ranges in job adverts, extending the directive’s requirement to provide this information before interviews; and second, employers are prohibited from asking applicants about their current or previous pay.
However, the bill as it stands does not meet all the directive’s conditions such as employee rights to pay information, so additional legislation will be required.
Current legislation for gender pay gap reporting was extended to companies with at least 50 employees on 1 June 2025 under the Gender Pay Information Act 2021.
Relevant legislation
Related commentary
Italy
Italy has no current proposal to transpose the directive. However, on 21 February 2024, Law No. 15/2024 (Italian language only) was published in Italy’s Official Gazette No. 46, authorising the government to issue implementing decrees to comply with the EU Pay Transparency Directive before the 7 June 2026 deadline.
Italy already has existing pay reporting requirements. The Code of Equal Opportunities 2021 (Italian language only) requires employers with 50 or more employees to report on gender and pay data every two years. These reports must also be shared with employee representatives. Italy will need to adjust reporting requirements for companies with 250+ employees from biennial to annual to comply with the directive.
Italy also has a gender equality certification scheme, incentivising companies to reduce gender inequality. Eligible companies may be allowed to reduce employer social security contributions and get preferential treatment for public contracts.
Relevant legislation
- Law No. 15/2024 (Italian language only)
- Code of Equal Opportunities 2021
- Gender Equality Certification System
Related commentary
Lithuania
In May 2025, the Ministry of Social Security and Labour presented a draft bill (Lithuanian language only) to partially implement the directive. It prevents employers from asking applicants about their previous salary during recruitment, gives employees the right to request information about their pay level and how it compares to comparable positions, and requires employers to develop pay structures based on gender-neutral factors. Pay gap reporting requirements will be handled separately through a process overseen by the social insurance and labour inspection institutions.
The proposals supplement Lithuania’s Labour Code 2002, which imposes pay reporting requirements for companies with more than 20 employees and requires employers to act if the pay gap exceeds 5%. Employers already must also provide salary range information for open roles and cannot ask applicants or employees about salary history.
Relevant legislation
Luxembourg
Luxembourg has no current proposal to transpose the directive.
There are existing internal reporting requirements for employers with 50 or more employees set out in the Labour Code 2006. They must provide biannual statistics broken down by gender to employee representatives.
The Ministry of Equality between Men and Women developed an online tool (French language only) in 2012 that helps employers identify the causes behind any pay gaps.
Relevant legislation
Malta
On 27 June 2025, the Maltese government published a legal notice announcing amendments to the Employment and Industrial Relations Act 2002 aligning with the directive.
Effective 27 August 2025, employers must implement gender-neutral pay structures, include salary ranges in job postings, and cannot ask questions about salary history during recruitment. Employees can request pay comparison data for categories of workers performing the same work as them, though the scope for this is narrower than the EU standard, which also includes those who perform “work of equal value.”
Relevant legislation
Related commentary
Netherlands
The Dutch parliament began the implementation process in March 2025 by debating proposed amendments (Dutch language only) to the Equal Treatment for Men and Women Act 2015.
The amendments essentially mirror the directive, addressing equal pay for work of comparable value, gender pay gap reporting requirements, and employee access to information. Notably, it also stipulates that in cases of pay discrimination, employers bear the burden of proof and must demonstrate that any differences in pay are not based on gender.
The bill is expected to be submitted to the Council of State before the end of 2025, followed by debate in the House of Representatives and then the Senate.
However, on 15 September 2025, the government indicated (Dutch language only) that full implementation of the directive will be delayed to 1 January 2027, missing the EU deadline of 7 June 2026.
Relevant legislation
- Consultation on Act on the Implementation of the Wage Transparency Directive for Men and Women (Dutch language only)
- Equal Treatment for Men and Women Act 2015
Related commentary
Poland
On 24 June 2025, legislation amending the Labour Code 1974 (Polish language only) was published, partially implementing the directive. It enters into force on 24 December 2025.
It focuses mainly on recruitment and salary information, namely enshrining gender-neutral job advertisements, banning questions on salary history, prohibiting salary ranges in job postings, and penalising slow responses to employee pay information requests.
The bill does not cover gender pay gap reporting obligations – but that is expected to be addressed in a separate legislative proposal.
Relevant legislation
Related commentary
Portugal
Portugal has no current proposal to transpose the directive.
Existing domestic laws (Act No. 60/2018) already mandate equal pay for equal work, or work of equal value, between women and men. Employers are already obliged to adopt transparent pay policies based on objective criteria, regardless of gender. Employers must also submit pay data through the Unique Report (Relatório Único; Portuguese language only) to the Ministry of Labour, Solidarity and Social Security.
On 7 January 2025, the Authority for Working Conditions notified 4,000 businesses (Portuguese language only) it identified as having gender pay disparities. These employers were given 120 working days to submit comprehensive pay gap assessment plans, including job function evaluations and corrective measures to be implemented over 12 months.
Relevant legislation
- Act No. 60/2018
- Unique Report (Portuguese language only)
Related commentary
Slovakia
On 19 September 2025, the Ministry of Labour, Social Affairs and Family published a new draft law (Slovak language only), transposing the directive, for public review until 9 October 2025. The law’s provisions will take effect on 1 June 2026 and include a ban on asking for salary history, employee rights to request pay data and phased reporting obligations for employers with at least 100 employees. Non-compliant employers may face administrative fines of up to €4,000 (US$4,670).
Relevant legislation
- Act on the Application of the Principle of Equal Pay for Men and Women for Equal Work or Work of Equal Value (Slovak language only)
Related commentary
Slovenia
On 1 December 2024, the Ministry of Labour, Family, Social Affairs and Equal Opportunities launched the PAY DAY project (Slovenian language only), to support the implementation of the directive.
The project will introduce a free online tool to provide gender pay gap information, develop guidelines for gender-neutral job evaluation systems, and offer training for key stakeholder groups.
In parallel, the Ministry has initiated the transposition of the directive into national legislation (Slovenian language only), by establishing two working groups, one of which is tasked with drafting a new law.
Relevant legislation
- PAY DAY project (Slovenian language only)
Related commentary
Spain
Spain has no current proposal to transpose the directive.
However, since 2021, national decrees have imposed some pay transparency measures, including requiring all employers to produce gender-disaggregated salary annual registers and – for companies with over 50 employees – equality plans with salary audits. These plans must include job evaluations and corrective actions where disparities exist, with justification required if pay gaps exceed 25%. The latter will need to be reduced to 5% to align with the directive.
Relevant legislation
- Royal Decree 901/2020 (Spanish language only)
- Royal Decree 902/2020 (Spanish language only)
Related commentary
Sweden
In May 2024, Sweden became the first EU member state to publish draft legislation (Swedish language only) implementing the directive, by amending its Discrimination Act 2008 (Diskrimineringslagen). The legislation is currently under consultation and is scheduled to be finalised in January 2026. As it currently stands, it aligns and, in many areas, surpasses the EU’s provisions. For example, Sweden plans to maintain its existing, more stringent reporting threshold for pay gaps, which applies to companies with at least 10 employees compared to the directive's 100+ employee threshold.
The draft also introduces new requirements for employers to provide job candidates with collective bargaining details relevant to the role ahead of salary negotiations, building on the directive’s minimum requirement for access to salary information. Additionally, it will mandate employers to include comparisons between women and men’s pay progression after taking parental leave in their annual equal pay salary reports. This exceeds the directive’s standard, which only demands family leave be factored in at the point of a joint pay assessment.
The new rules should come into force on 7 June 2026.
Relevant legislation
- Implementation of the Pay Transparency Directive (Swedish language only)
- Discrimination Act 2008
Related commentary