In a move that went under the radar in November 2025, Cyprus’s Department of Labor Relations published its draft legislation to transpose the EU Pay Transparency Directive (EUPTD).
The draft, titled, “Strengthening of the Implementation of the Principle of Equal Pay between Men and Women for Equal Work or Work of Equal Value through Wage Transparency and Enforcement Mechanisms Law of 2026” included a public consultation period that closed Dec. 4, 2025.
If enacted, the law would transpose the Directive largely word-for-word, adhering closely to the minimum requirements set out in Directive (EU) 2023/970, with limited national deviation.
Below is what employers should know.
Scope and Transposition Approach
Cyprus’s draft law mirrors the structure and substance of the EUPTD, with no indication of “gold-plating” or expansion beyond EU minimum standards.
Key elements addressed in the draft include:
- Pay transparency before employment
- Right to information (RTI) for workers
- Gender pay gap reporting and joint pay assessments (JPAs)
- Enforcement mechanisms and penalties
The draft confirms Cyprus’s intent to align tightly with the Directive rather than introduce additional national obligations.
Definition of “Wage”
The draft law adopts the EUPTD’s broad definition of pay, covering remuneration in cash or in kind.
However, for the purposes of:
- Right to information requests
- Gender pay gap reporting
- Joint pay assessments
the definition excludes certain items, including:
- Payments made in the event of dismissal
- Lump-sum retirement payments
- Occupational pensions financed by voluntary employee contributions
This clarification appears in Article 2 and represents one of the few areas where Cyprus has provided explicit interpretive guidance within the Directive’s framework.
Pay Transparency Before Employment
The draft confirms Cyprus’s alignment with Article 5 of the EUPTD.
Employers must disclose:
- The initial pay level or pay range for a position
If this information is not included in the job posting, it must be:
- Provided in writing
- Before the job interview takes place
This ensures candidates can engage in informed and transparent pay negotiations, consistent with the Directive’s intent.
Right to Information (RTI)
Cyprus’s draft law adopts the Directive’s RTI provisions without modification.
Key points include:
- Workers may request information on their own pay level and average pay levels, broken down by gender, for work of equal value
- RTI deadlines and procedural requirements align with Article 7 of the EUPTD
- No additional national deadlines or procedural layers are introduced
Responses to Requests and Data Clarifications
Employers with 100 or more employees must submit pay reports under Article 10, which aligns with the reporting requirements of Article 9 of the EUPTD. Where employees request additional explanations or clarifications regarding reported data, employers must provide a substantiated response:
- Within one (1) month of receiving the request
- As specified in Article 10(10)
This requirement reinforces the Directive’s emphasis on meaningful transparency, not merely formal disclosure.
Joint Pay Assessments
Cyprus’s draft law mirrors the Directive’s joint pay assessment framework exactly.
- JPAs are triggered where unexplained gender pay gaps of 5% or more are identified
- Requirements and timelines follow Article 11 of the EUPTD
- No additional national conditions or exemptions are introduced
Safeguards Against Individual Pay Disclosure
To prevent the direct or indirect identification of individual pay, Article 13 introduces a protective mechanism:
If disclosure could reveal an individual’s pay level:
- Information must be provided only to:
- Employee representatives
- The Labour Inspector
- The Commissioner for Administration
These bodies may then advise the employee regarding a potential claim without disclosing specific pay figures of individual employees.
This approach balances transparency rights with data protection concerns.
Enforcement and Penalties
A unique wrinkle in Cyprus’ draft is its proposed enforcement and penalties, which go well beyond what other member states have proposed.
Under Article 27, violations may result in:
- Imprisonment for up to six months, or
- A fine of up to €10,000, or
- Both
Courts may also:
- Order the employer to cease the violation
- Mandate remedial measures, including compensation
For continued non-compliance, recurring fines may be imposed. Importantly, liability may extend beyond the legal entity to:
- Advisors
- Presidents
- Directors
- Secretaries or similar officers
This is the case unless it is proven that the offense occurred without their consent, complicity, or negligence.
What Comes Next
With the consultation period now closed, employers should expect further legislative movement in 2026.
Given Cyprus’s close adherence to the Directive’s minimum requirements, organizations operating in Cyprus — or with employees based there — should assume that full EUPTD compliance obligations will apply on the EU timeline and begin preparing accordingly.
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 inequities to determine if your adjusted gender pay gap is above 5%. It enables you to easily comply with Article 7 (right to information) and Article 6 requirements (pay setting and progression policy).
- Our Remediation Optimization Spend Agent (R.O.S.A.) works as PayParity’s AI remediation partner to find the most cost-effective way to close nominal pay gaps above 5% to ensure compliance.
- Salary Range Finder ensures equitable pay at the point of hire to prevent your pay gap from rising above 5% 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 Pay Transparency Reporting™ captures your pay equity findings and generates compliant, one-click reports across all EU jurisdictions.
- Our Pay Transparency Agent answers all your pay transparency reporting questions instantly.
- Our Communications Agent crafts perfect contextual narratives in any EU language to support your annual pay 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.
Visit our always updated Member State Transposition Monitor to stay on top of the latest EU Pay Transparency Directive developments.
