EU Pay Transparency Directive: Member State Transposition Monitor

Despite recent EU Commission statements that it is not open to such requests, Belgium (Federal) has requested a six-month extension from the Commission to transpose the Directive due to stalled negotiations with the National Labour Council. Specific concerns:

• Privacy / GDPR
• The broad definitions of “pay” and “worker”
• Retroactively needing to justify salary history

Belgium Flemish Region: In the Committee on Social Affairs, Employment, and Pensions, in the week of 13 April, Minister Clarinval confirmed Belgium’s intention to fully transpose the EUPTD into Belgian law by June 7, 2026. A draft has not yet been submitted but is in the works. We will update when it becomes available.

Belgium (French Community): Right to Information and General Pay Transparency requirements transposed for the public sector in the French Community.

• The short draft law – the Law on Amendment and Supplement to the Protection against Discrimination Act – aims to transpose the requirements of the Directive through amendments to the Protection against Discrimination Act and Labour Code.

Announcement Pending

The Labor Relations Department in November 2025 released “The Strengthening of the Implementation of the Principle of Equal Remuneration between Men and Women for Equal Work or Work of Equal Value, through Wage Transparency and Enforcement Mechanisms Law of 2026.” Comments on the draft bill were available until 4 December 2025. It targets a full transposition by the 7 June 2026 deadline.

On 16 March 2026 the Ministry of Labour and Social Affairs introduced Czechia’s draft law to transpose the Directive. The draft targets a 1 January 2027 implementation date with first pay gap reporting beginning in 2028.

A partial transposition covering a ban on salary history inquiries has already been implemented.

On 26 February 2026 Denmark released its draft legislation to transpose the EU Pay Transparency Directive. It plans to implement it into law 1 January 2027 — six months past the June 2026 deadline.

On 16 April 2026, Estonia announced it would seek a potentially multi-year postponement and amendment of the EUPTD.  Estonia’s Minister of Economic Affairs and Industry has stated that Estonia would rather pay a fine to postpone the EUPTD transposition in Estonia rather than increase the burden on businesses.

Shortly after that announcement, the government decided in a cabinet meeting on a partial reversal of course, moving forward with a plan to strengthen legal clarity around the existing right to equal pay for equal work and incorporating certain EUPTD pre-employment pay transparency rights into Estonian law, such as the ban on asking an applicant for their salary history and the right to receive initial pay information before an interview.  The draft of this law is to be submitted to the cabinet in April.

The Finnish government had originally targeted at May 18, 2026 implementation. However, that deadline will now be missed, and Finland will miss the 7 June 2026 deadline. The estimated week for the government proposal to be presented has been updated from Week 16 of 2026 (13 April – 19 April) to Week 25 (15 June – June 21).

The government’s “Situation description” noted: “The implementation of the Pay Transparency Directive is delayed and the entry into force of the national legislation depends on the parliamentary processing schedule.” 

On 16 May 2025, Finland published its draft legislation to implement the EU Pay Transparency Directive. Access the draft bill for more details.

On 4 June 2026 the Ministry of Labour sent a new draft of its transposition legislation to social partners.  Articles on the civil service will be submitted to the CCFP (conseil commun de la fonction publique) on 18 June. This round of consultations will precede presentation to the Council of Ministers so France is still in the consultation phase. The main difference between this version and the version from March is the inclusion of Title II, which covers public sector employers.

The law continues to enter into force on a date set by decree, and at the latest within one year of promulgation of the law, but anticipates a phased entry into force of reporting obligations for smaller employers: 100-149 employees (within three years); 50-99 employees (within 6 years).  Ultimately, these dates will be set by decree.

• • The current legislative term in Germany is the 21st Bundestag which is scheduled to end on March 25, 2029, unless there is an early dissolution of parliament.
  • In other words, the Ministry has stated that it will transpose the Directive sometime before March 2029.
  • The Ministry did not clarify when a draft transposition could be expected but the goal is by the end of 2026.

Germany’s Commission on “Low-Bureaucracy Implementation of the Pay Transparency Directive” released its report recommending how to transpose the EU Pay Transparency Directive 29 October 2025. An official draft based on the 11-person Commission’s recommendation is now underway and is scheduled for cabinet approval by the end of February 2026.

• • Pre-employment pay transparency before interview
  • When a collective labor agreement (CLA) is applied, there is a presumption that there is no unjustified wage discrimination; CLAs can also be used as a basis for creation of compliant pay structures
  • The draft legislation incorporates 65 proposals submitted by social partners

Announcement Pending

February 2026 update: Ireland’s employer lobbying group, IBEC, has formally called for a one-year delay in the government’s obligation to implement the Directive by June 2026. We will monitor and update as the situation evolves.

Ireland published its draft bill implementing the pay transparency provisions of the EU Pay Transparency Directive on 15 January 2025. Access the draft bill and our webinar for more details

Italy published its legislative decree in the Gazetta Ufficiale. It enters into force 7 June 2026.

Italy’s Council of Ministers approved in final examination on 30 April 2026 the draft legislative decree.  Access draft legislation here.

Latvia on published its draft legislation to transpose the EU Pay Transparency Directive. The consultation period will close 9 April 2026 before moving to the Cabinet of Ministers and then to the Saeima for parliamentary consideration.

The Luxembourg government recently launched a consultation of a preliminary draft transposition bill within the Ministry of Labour. 

As of 15 May 2026 no official draft bill has been filed with the Chamber of Deputies. Despite this movement, given timing constraints, Luxembourg will not meet the June 2026 implementation date.

Malta published 5 June 2026 the Equal Pay (Transparency and Reporting) Regulations, 2026 to fully transpose the Directive. This new regulations are of immediate effect and cover all Directive requirements. Those that were previously partially transposed (e.g. RTI) have now been brought in line with the Directive.

1. Initial pay transparency: requiring information to be provided prior to the commencement of employment.
2. RTI: requiring an employer to provide an individual’s pay level and the pay levels of those employees performing the “same” work as them (concept of equal value not explicitly stated). It did not require a breakdown by gender.

On 15 September 2025, the Dutch government announced plans to delay implementation of the Directive for employers with 150 or more employees to 1 January 2027. We will monitor whether this will receive pushback from the European Parliament or Commission.

• Reminder: In June 2025 Poland amended its Labour Code to transpose certain pre-employment transparency requirements, effective 24 December 2025.
• Update:  On 4 May 2026, Poland published an updated draft of its transposition of remaining requirements based on comments received during the consultation period on its December 2025 draft of remaining requirements that concluded in January.
  • Next steps: review by committees of the Council of Ministers before Council of Minister approval for referral to the Sejm (parliament). Current status and documentation can be found here.
• Delayed entry into force: Under Art. 74 of the draft law it would enter into force 6 months after its publication, confirming earlier signals by the Ministry that transposition would be delayed.
• Right to Information:
  • Draft maintains 30-day deadline to respond to initial RTI requests and requests for supplementation in case of inaccurate or incomplete information.
    • Employee must specify the scope of information considered to be inaccurate or incomplete.
  • Timeframe: Pay levels are to be calculated for the period of 12 months for which the remuneration was paid, preceding the month of submission of the application.

No official announcement has been provided from Portugal Labour officials. Stay tuned for more details.

Romania’s Ministry of Labour, Family, Youth and Social Solidarity on 30 March, 2026 published its draft legislation to transpose the EU Pay Transparency Directive.

President Peter Pellegrini on April 23, 2026 signed the Act on Equal Remuneration of Men and Women for Equal Work or Work of Equal Value. On May 8, 2026, it was transposed into law.

It will take effect 7 June, 2026. Slovakia is the first member state to transpose the Directive into law. The legislative history can be found here.

The Ministry of Labour, Family, Social Affairs and Equal Opportunities has initiated a working group to develop the draft legislation to implement the Directive. No timetable has been publicized on its release.

The Government has approved the Annual Regulatory Plan (Plan Anual Normativo), which includes the transposition of the Directive (p. 48).  This is the roadmap of the legislative initiatives each ministerial department plans to submit each calendar year to the Council of Ministers for approval.

On 26 March 2026, Sweden announced it’s putting its transposition efforts on hold and will be seeking a postponement and renegotiation of the Directive.

On 11 March 2026, Sweden announced it is further delaying its transposition to 1 January 2027. The first reporting deadline is being moved to 20 May 2028. We will have more analysis in a forthcoming blog.

 Access our analysis about what will be required in our prior blog.