On March 16, 2026, Czechia’s Ministry of Labour and Social Affairs (MoLSA) introduced a draft law to transpose the EU Pay Transparency Directive (EUPTD). The draft was published for public consultation on March 26, 2026, with comments open through April 27, 2026.
The proposal sets a Jan. 1, 2027 general entry into force date, but most substantive obligations — including Right to Information (RTI), pay reporting, and Joint Pay Assessments — would not take effect until Jan. 1, 2028, with certain provisions entering into force in 2031.
A Minimalist, System-Integrated Approach
Czechia’s transposition strategy is notably pragmatic. Rather than building an entirely new compliance framework, the draft aims to preserve existing legal structures and introduce Directive requirements in a way that aligns with current legislation and national practices.
This is achieved primarily through targeted amendments to:
- The Labour Code
- The Labour Inspection Act
- The Anti-Discrimination Act
- Select sector-specific laws
A defining feature of the proposal is its reliance on existing monthly reporting mechanisms, particularly the Unified Monthly Employer Report (JMHZ). By leveraging infrastructure already in place, Czechia is attempting to reduce incremental administrative burden for employers while still meeting Directive requirements.
The result is a minimalist transposition that adheres closely to the Directive without introducing significant national expansion.
Pre-Employment Transparency: Focus on Minimum Pay Disclosure
Czechia’s draft introduces pre-employment transparency requirements through amendments to the Labour Code, with a particular emphasis on timing and clarity.
Employers will be required to provide minimum salary or wage information before the start of employment negotiations, and the explanatory notes make clear that this obligation must be fulfilled prior to the interview stage. In practice, this means that employers will need to ensure candidates have access to pay information early in the hiring process.
The legislation also provides flexibility in how this obligation is met. If an employer voluntarily includes minimum pay in a job advertisement, that disclosure may satisfy the requirement, provided it is sufficiently clear to withstand potential review by authorities or courts.
While the draft aligns with the Directive’s salary history ban, it does not prohibit all compensation-related inquiries. Employers may still ask candidates about their salary expectations, but only after the required pay information has been provided.
Overall, Czechia adopts a targeted implementation that requires transparency, but limiting it to minimum pay rather than broader salary ranges.
Equal Work and Pay Structures: Reinforcing Existing Legal Foundations
Czechia already has a well-established legal framework for equal pay, and the draft builds on this foundation rather than redefining it.
The concept of “equal work or work of equal value” remains aligned with existing Labour Code provisions, which define comparability based on:
- Complexity of work
- Responsibility
- Effort
- Working conditions
- Performance and results
Importantly, this is framed as an exhaustive list of criteria, providing employers with clear parameters for setting and evaluating pay.
The draft also introduces a more structured requirement for pay systems under Section 109a, including the division of roles into defined work categories. Employers will continue to be required to engage with trade unions on remuneration systems, reinforcing the role of worker representatives in pay governance.
To support implementation, MoLSA plans to provide a job evaluation tool to help employers assess the value of work. However, use of this tool will be voluntary, preserving employer flexibility in methodology.
Strengthening Comparator Frameworks for Equal Pay Claims
Through amendments to the Anti-Discrimination Act, Czechia expands how employees can establish comparators in equal pay claims.
The draft makes clear that comparisons are not limited to existing employees within the organization. Instead, employees may rely on:
- Statistical evidence
- Hypothetical comparators
- Shared remuneration frameworks across multiple employers
This is a meaningful shift. By broadening the scope of comparators, consistent with Article 19 of the Directive, Czechia lowers the evidentiary barrier for employees bringing claims, particularly in organizations or roles where direct comparators are limited.
Scope of Workers: Broad Coverage with Nuanced Treatment of Temporary Workers
The draft applies broadly across employment relationships, covering not only traditional employees but also individuals working under so-called non-employment agreements used for flexible or part-time work, such as agreements on work activity (DPČ) and agreements on work performance (DPP).
Temporary agency workers are also included, though their treatment reflects the complexity of their employment structure. While they are formally employed by agencies, they perform work for user employers. The draft reinforces the principle that their pay conditions must be at least equivalent to comparable employees of the user organization for the period of their work for that organization.
From a compliance standpoint, temporary workers will be fully integrated into reporting and transparency requirements beginning in 2031, with cooperation required between agencies and user employers to ensure accurate data and equal treatment. Temporary workers will be considered employees of the user employer as of that date, except for the purposes of reporting data under the JMHZ, which the employment agency will complete.
Right to Information: Structured Implementation with Strong Safeguards
Right to Information obligations will take effect in 2028, based on data from the previous calendar year. Czechia is the first EU Member State to specify the time frame of the pay data that must be used for this requirement, which removes a degree of ambiguity that exists around RTI in Czechia compared to other draft legislation.
Upon written request, employees will be entitled to receive:
- Their own pay information
- The average pay of comparable roles
- A gender-based breakdown of that data
These will be expressed in gross annual terms for the previous calendar year and in corresponding gross hourly terms. MoLSA will establish by decree the method for calculating the amount of remuneration for RTI purposes. Employers must respond within two months, and if employees request clarification, a further response must be provided within two months of that follow-up request.
The draft also introduces several procedural elements designed to standardize RTI processes. Requests may be submitted not only directly to employers, but also through worker representatives or the Public Defender of Rights. Employers will also be required to provide annual reminders to employees about their RTI rights using customary and accessible internal communication channels.
There are important limitations as well. New employees cannot submit RTI requests until after the end of the calendar year. Additionally, employers may restrict how RTI data is used, limiting it to the exercise of equal pay rights if specified in writing.
Privacy and Confidentiality
Czechia places a strong emphasis on protecting individual privacy. If fulfilling an RTI request would reveal the pay of an identifiable employee, the information must instead be provided to the Public Defender of Rights. The requesting employee is then informed of this alternative process without undue delay.
This approach reflects a careful balancing of transparency obligations with data protection considerations.
Reporting Obligations: Efficiency Through Existing Infrastructure
One of the most distinctive aspects of Czechia’s draft is its approach to pay reporting.
Rather than requiring employers to generate full reports independently, the Ministry will use data already submitted through the Unified Monthly Employer Report (JMHZ) to prepare baseline pay gap reports on behalf of employers.
Employers will still retain responsibility for reporting pay gaps by worker category, which cannot be derived solely from existing datasets. These reports must be submitted annually by April 30, following consultation with worker representatives. MoLSA will establish by decree the prescribed methodology and form of the reporting.
Reporting cadence is aligned with the Directive but phased in over time:
- 250+ employees: annual reporting beginning in 2028
- 150–249 employees: every three years starting in 2028
- 100–149 employees: every three years starting in 2031
Employers will be notified each year by Feb. 28 if they fall within a reporting category.
This model significantly reduces administrative lift while maintaining accountability for detailed pay gap analysis.
Joint Pay Assessments: Clear Timelines and Governance Expectations
Czechia’s approach to Joint Pay Assessments closely mirrors the Directive, with added procedural clarity.
A Joint Pay Assessment is triggered when a 5% pay gap, measured in hourly terms, is identified in any worker category and cannot be justified. Employers are given six months to remediate the gap. If it remains unresolved, a Joint Pay Assessment must be completed within the following two months.
The draft also establishes clear expectations for involving worker representatives. Employers must conduct assessments in consultation with trade unions or works councils. If none exist, the employer must publicly notify employees of the obligation to conduct a Joint Pay Assessment and allow time for representation to form before proceeding.
Enforcement and Penalties
The draft introduces a tiered penalty framework, with fines scaled based on the severity of non-compliance.
Lower-level violations, such as failures related to pre-employment transparency or consultation obligations, may result in fines of up to CZK 200,000. More significant breaches — including RTI non-compliance or deficiencies in benefits systems — can reach CZK 400,000. The most serious violations, such as failure to establish compliant pay structures, meet reporting obligations, or complete a Joint Pay Assessment, may result in fines of up to CZK 1 million.
In parallel, employees are granted robust rights under the Anti-Discrimination Act to pursue equal pay claims, including the right to compensation for both financial and non-financial harm, as well as back pay and corrective adjustments.
How Trusaic Can Help
At Trusaic, we provide employers across the EU with solutions to comply confidently with the Directive.
Our Complete EU Pay Transparency Solution enables compliant pay systems, ensures gender-neutral job evaluations, and automates complex reporting obligations to keep you one step ahead of EU pay transparency enforcement.
- PayParity® analyzes your rewards data (compensation/benefits in kind) and quickly identifies any potential unjustified inequities. It enables you to more easily comply with Article 7 (right to information) and Article 6 requirements (pay setting and progression policy).
- Our Remediation Optimization Spend Analysis (R.O.S.A.) works as PayParity’s remediation engine to find the most cost-effective way to close nominal pay gaps to ensure compliance.
- Automated RTI workflows: Our bi-directional integrations with global HCM platforms allow pay equity data to flow securely from the Trusaic platform back into the HCM. Employees can then access their RTI reports directly within their existing HR systems. This eliminates manual report generation and reduces compliance risk.
- For organizations that prefer platform-based access, RTI reports can also be generated and delivered securely through the PayParity platform, with role-based permissions and full auditability.
- Salary Range Finder® ensures equitable pay at the point of hire to prevent any increases in pay gap and enables you to easily comply with the Directive’s salary range disclosure and salary history ban requirements.
- Pay Decisions: Generate fair, competitive offers instantly from Workday.
- Regulatory and Pay Transparency Reporting™ captures your pay equity findings and generates compliant reports.
Trusaic is GDPR compliant and can assist any organization in any EU state in meeting its obligations under both the EU Corporate Sustainability Reporting Directive and the EU Pay Transparency Directive.
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