Finland has moved closer to its EU Pay Transparency Directive transposition, submitting Government proposal HE 129/2026 vp to the Finnish Parliament on 9 July 2026.
The submission follows Finland’s missed 7 June 2026 transposition deadline, which was originally targeted for 18 May 2026, and confirms the substance of the draft that emerged from the government’s public comment process earlier this year. The proposal primarily amends the Act on Equality between Women and Men, but also proposes amendments to the Act on the Ombudsman for Equality, the Act on the Incomes Information System, the Act on Statistics Finland, and the Act on the Enforcement of Fines.
All five amended acts are intended to enter into force on 1 January 2027. Parliament is reported to begin its consideration of the draft in the fall of 2026.
What Does Finland’s Draft Legislation Propose?
Finland’s covered-employer thresholds largely align with the Directive, with one notable divergence: the first reporting deadlines for employers with 150 or more employees fall after the Directive’s own 7 June 2027 deadline for large employers.
- 250+ employees: first report due 2 May 2028 (for 2027 data), then annually
- 150–249 employees: first report due 2 May 2028 (for 2027 data), then every three years
- 100–149 employees: first report due 2 May 2031 (for 2030 data), then every three years
- Under 100 employees: reporting not required (voluntary)
Consistent with the approach in earlier drafts, Finland is leveraging its existing Incomes Register infrastructure for reporting. Statistics Finland will compile six of the seven required gender pay-gap indicators directly from payroll data already reported to the Incomes Register.
The one indicator employers must calculate and submit themselves is the category-level pay-gap analysis, which is also the figure that can trigger a Joint Pay Assessment.
The draft also adds two definitions to Section 3 of the Act on Equality between Women and Men that anchor the new reporting and assessment obligations. “Gender pay gap” is defined as the difference between the average pay levels of an employer’s female and male workers, expressed as a percentage of the male workers’ average pay level. “Category of workers” is defined as workers performing equal work or work of equal value whom the employer has grouped, in a non-arbitrary manner, using non-discriminatory, objective, and gender-neutral criteria, and, where applicable, in cooperation with personnel representatives.
How Does the Draft Address the Right to Information?
The RTI provisions are largely aligned with the Directive and apply universally, regardless of employer size:
- Who can request, and what: Any worker may request, in writing, their own pay level and the sex-disaggregated average pay for categories performing equal work or work of equal value.
- Response window and channels: Employers must respond within a reasonable time, and no later than two months. Requests may be routed through a personnel representative or the Ombudsman for Equality, and workers with disabilities must receive the information in accessible form.
- Anonymity safeguard: If category averages would reveal an identifiable co-worker’s pay, the employer must still provide the data — but to a personnel representative or the Ombudsman instead of directly to the requesting worker.
- Follow-up rights: Workers may request reasonable additional information about the data provided, and employers must give a justified response.
- Annual notice: Employers must inform workers each year that this right exists and how to exercise it.
- Pay-secrecy ban: Contract terms prohibiting workers from disclosing their own pay are void, though workers may be limited to using others’ pay data only to investigate potential pay discrimination against themselves.
- Enforcement: Non-compliance reverses the burden of proof onto the employer and can lead to a Tribunal compliance order backed by a conditional fine.
When Would a Joint Pay Assessment Be Triggered?
As with the Directive, all three of the following conditions must be met before a Joint Pay Assessment is required:
- A gender pay gap of at least 5% within any single category of workers performing equal work or work of equal value — measured at the category level, not organization-wide.
- The employer has not justified that difference using objective, gender-neutral criteria.
- The employer has not remedied the unjustified gap within six months of the date by which Statistics Finland was required to transmit the pay-gap data to the Ombudsman for Equality.
What Other Laws Does the Draft Amend?
Beyond the Equality Act, the draft proposes coordinated amendments across four additional statutes:
- Act on the Ombudsman for Equality: Adds five new tasks, including promoting pay-transparency awareness, analyzing the causes of gender pay differences, publishing employer pay-gap data (with four years of historical comparison), receiving Joint Pay Assessments, and compiling statistics on pay-discrimination matters before the Ombudsman, the Tribunal, and the courts.
- Act on the Incomes Information System: Adds the pay-gap data points employers and the government need to generate the required indicators, sets an end-of-April submission deadline, and phases in employers with 100–149 employees starting 1 January 2030.
- Act on Statistics Finland: Designates Statistics Finland to produce the expert services needed to create and transmit the pay-difference data required under the Equality Act.
- Act on the Enforcement of Fines: Adds the new negligence fee (EUR 5,000–80,000, imposed on employers that fail to submit a Joint Pay Assessment on time) to the list of administrative sanctions enforceable under the fine-enforcement regime.
What Happens Next?
With the draft now before Parliament, the timeline shifts to the legislative process. Parliament is expected to begin its review in the fall of 2026, ahead of the proposed 1 January 2027 entry into force across all five acts. Until the national legislation takes effect, employers’ obligations in Finland continue to be governed by existing law.
Trusaic will continue to track RP 129/2026 rd as it moves through Parliament and provide updates on any changes to scope, deadlines, or the reporting framework described above.
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.
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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