Finland is moving closer toward transposing the EU Pay Transparency Directive (Directive (EU) 2023/970), with recent developments clarifying both timing and substance of the forthcoming national legislation.
Finland’s Ministry of Social Affairs and Health officially requested comments on Dec. 22, 2025 on its draft government proposal, which builds off of the working group’s proposed transposition from May 2025. Employer groups will have until Feb. 9, 2026 to provide comments.
The government expects to submit its proposal to Parliament in spring 2026 and has proposed that the law enter into force on May 18, 2026.
Core Elements of Finland’s Proposed Law
Finland’s draft legislation closely mirrors the minimum requirements of the EU Pay Transparency Directive, while applying several transparency rights universally across employers.
Pay Transparency in Recruitment
Employers will be required to:
- Provide job applicants with starting salary or salary range information during the recruitment process.
- Refrain from asking applicants about salary history, preventing prior inequities from influencing future pay.
While salary ranges do not need to appear directly in job postings, employers must ensure that this information is shared in a timely and transparent manner during hiring.
Employee Right to Information
Employees will gain the right to request information on:
- Their individual pay level, and
- The average pay levels by gender for employees performing the same work or work of equal value.
Employers must respond within two months of receiving a request. These requirements reinforce Article 7 of the Directive and will require employers to maintain accurate, defensible job structures and pay data.
Pay Gap Reporting and Employer Obligations
Reporting Thresholds and Scope
Employers with 100 or more employees will be subject to gender pay gap reporting obligations, including:
- Median and mean gender pay gaps
- Gender distribution across pay quartiles
- Breakdowns of variable pay components
- Pay gap tables by job category, prepared by employers and shared with employee representatives and the workforce
Employers must also retain pay gap data for at least four years, and provide it upon request.
Reporting will follow the Directive’s phased thresholds:
- 250+ employees – Annual reporting
- 150–249 employees – First report due on June 7, 2027 and every three years thereafter
- 100–149 employees – First report due on June 7, 2031 and every three years thereafter
After the first reporting year, reports must be submitted by the end of April each reporting year.
In addition, employers with 50 or more employees will be required to formally define and document pay progression criteria, providing greater transparency around promotions and compensation development.
Centralized Data Collection, Employer-Led Execution
To reduce administrative burden, Finland plans to leverage centralized data sources such as the Tulorekisteri (Income Register) and national statistical databases to collect baseline pay data.
However, employers will remain responsible for, inter alia:
- Analyzing and submitting data on category-specific pay gaps
- Distributing required disclosures internally
- Responding to information requests
- Conducting joint pay assessments where unjustified gender pay gaps of 5% or more are identified
This hybrid approach combines centralized data efficiency with employer accountability under the Directive.
Defining Work of Equal Value: Section 3a
A key refinement to Finland’s proposal is the introduction of Section 3a, which clarifies how equal work and work of equal value must be assessed.
Work of equal value will be evaluated using objective, gender-neutral, and work-relevant criteria, including:
- Competence and qualifications
- Workload
- Responsibility
- Working conditions
- Other factors relevant to the role
The relative weighting of these criteria may vary depending on the nature of the work. Where employers are bound by collective or employment agreements that already define job evaluation criteria using objective and gender-neutral standards, those frameworks may be used to assess equal value.
Enforcement and Penalties
Finland’s proposal introduces a robust enforcement regime, with administrative omission fees ranging from €5,000 to €80,000, depending on:
- Company turnover
- Severity and duration of the violation
Fines may be imposed for:
- Failing to conduct or submit a joint pay assessment
- Submitting a joint pay assessment that does not substantially comply with requirements
These penalties do not include back pay or damages, which may still be pursued separately through legal claims—underscoring the importance of proactive compliance.
What Employers Should Do Now
With implementation expected in May 2026 and consultation nearing completion, employers operating in Finland should begin preparing now by:
- Reviewing job architecture and job evaluation frameworks
- Ensuring salary range practices align with transparency requirements
- Auditing pay data readiness for reporting and right-to-information requests
- Aligning pay progression criteria with objective, gender-neutral standards
Finland’s approach reflects a broader EU trend: minimum transposition does not mean minimal effort for employers. The operational lift required to meet these obligations is substantial — and the timeline is tightening.
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.
