While actual EU Pay Transparency Directive transposition activity remains mostly static, adjacent updates continue to trickle out of Member States in October.
In a follow-up to our previous October roundup blog, there have been additional developments in Lithuania, Czechia, Finland, and Spain.
Lithuania’s Sodra Publishes RTI and Reporting Guidance
Sodra, Lithuania’s State Social Insurance Fund Board, published additional guidance on its website ahead of required employer monthly data submissions beginning in February 2027 (for January 2027 data).
Sodra, which will oversee calculations for both gender pay gap reporting and RTI, has two key distinctions in its approach:
- Sodra will calculate RTI averages
- RTI responses must include monthly average figures
Employers with at least eight employees, including more than three women and three men, will also have their average hourly pay by sex publicly disclosed and updated monthly.
Key dates to track:
- 28 February 2027: First employer data submission deadline, covering 1 to 31 January 2027
- 1 March 2027: Employees may begin requesting their own and comparative monthly average hourly pay from their employer, employee representatives, the Labour Inspectorate, or the Equal Opportunities Ombudsperson’s Office. Responses are due within a month.
- 15 March 2027: Sodra begins providing employers monthly worker-category averages (then monthly thereafter)
- 1 March 2028: Employees become entitled to request annual pay figures
- 15 March 2028: Sodra begins providing employers annual indicators
- 1 April 2028: Public disclosure of company-wide metrics begins for employers with 150 or more insured persons; employers receive their pay gaps by worker category
- 1 April 2031: Public disclosure of company-wide metrics begins for employers with 100 to 149 insured persons
Employers will submit paid working hours, accrued salary, and additional wages monthly, along with one-time data on working time norms, working time regime, and job group number (updated only when it changes).
Submissions go through the employer’s Sodra account using a new “Skaidraus darbo užmokesčio pranešimo” (SDUP) notification form, either completed directly or submitted via system integration; no electronic signature is required. Sodra has published a data structure description and a JSON schema validation file for employers planning to integrate directly.
Czechia’s Bill Advances to Committee on a Shortened Timeline
On 20 October 2026, Czechia’s Chamber of Deputies held the first reading of its EUPTD transposition bill and referred it to the Committee on Social Policy as the lead committee.
The Chamber shortened the committee’s consideration window to 30 days, down from the usual 60, signaling an effort to keep the bill moving.
After the Chamber’s remaining readings, the bill moves to the Senate, which has 30 days to decide once the bill is referred.
Finland Clarifies Reporting Mechanics and Pay Gap Presentation
Finland’s Incomes Register held a webinar on 15 October where it clarified its previous gender pay gap reporting guidance, which our 13 October blog covered.
Rather than reporting a gap as a negative number or stating which sex is paid more, it will report women’s average pay as a percentage of men’s. A 12.5% Directive-defined gap is reported as 87.5% (rounded to 88); no gap is reported as 100; and a figure above 100 means women are paid more. An earlier worked example that reversed this formula has since been corrected.
The Incomes Register’s remit covers reporting only, not RTI. However, its approach to worker categorization is directly relevant to RTI as well, since the underlying definition is shared. While the Register isn’t the official interpretive authority for the legislation, its guidance on which pay components to include and exclude can similarly inform a good-faith RTI compliance approach, even for employers below Finland’s reporting thresholds.
Spain’s Snap Election Raises a Timing Question
Spain’s snap general election, called for 29 November 2026, has suspended parliamentary proceedings. That may not affect the timeline for Spain’s draft transposition decree, since that royal decree will proceed through the executive branch rather than parliament.
Spain’s draft decree partially transposes the Directive by amending Royal Decree 902/2020.
As always, access our Transposition Monitor for the latest across all EU Member States.
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 supports GDPR compliance 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.
