Note: On June 27, 2025, Malta published Legal Notice 112 of 2025, marking its first official move toward transposing the EU Pay Transparency Directive (EUPTD). The provisions will come into force on Aug. 27, 2025, introducing foundational pay transparency measures in advance of the Directive’s full implementation deadline of June 7, 2026.
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Malta reporting requirements
Who needs to report?
Legal Notice 112 of 2025 does not yet require organizational-level gender pay gap reporting. However, under the EUPTD, Malta is expected to adopt phased reporting obligations:
- 250+ employees: Annual reporting beginning in 2027 (for 2026 data)
- 150–249 employees: Every three years starting in 2027
- 100–149 employees: Every three years beginning in 2031
- Fewer than 100 employees: Not currently required to report, unless Malta lowers the threshold
What to report?
Malta has not yet published detailed reporting requirements. Based on the Directive, future obligations will likely include:
- Mean and median gender pay gaps for total and variable pay
- Gender distribution across pay quartiles
- Proportion of employees receiving variable components by gender
- Gender pay gaps by job category
- Joint Pay Assessments when unjustified gaps ≥ 5% are detected
Legal Notice 112 currently focuses only on:
- Pre-employment disclosure of initial pay or pay range
- Right of employees to request their individual pay and pay of comparable workers (same work only)
Where and when to report?
The EUPTD requires that gender pay gap reports be submitted to a national authority and made publicly accessible. Malta has not yet designated a reporting platform or authority. Updates will be provided once further legislation is released.
Internal & Public Disclosure
Employers will be required to:
- Certify report accuracy
- Consult worker representatives
- Share findings with employees and publish results
Deadlines and Cadence
Reporting deadlines will align with EU Directive thresholds once Malta introduces full reporting legislation.
Malta pay transparency requirements
Effective August 27, 2025, employers must comply with:
- Salary range disclosure: Must provide the starting salary or pay range to job applicants before employment begins
- Collective agreement transparency: Where applicable, employers must disclose relevant collective agreement pay provisions
- Right to information: Employees may request their individual gross annual/hourly pay and the pay levels for workers performing the same work
- Response time: Employers must respond to requests within a maximum of two months
These measures support the EUPTD’s goal of improving pay transparency during recruitment and employment. However, Legal Notice 112 currently limits comparison rights to the “same work” rather than the broader “same or work of equal value.”
Employment equity standards
Malta enshrines equal pay principles under Article 27 of the Employment and Industrial Relations Act, which guarantees equal pay for equal work. Legal Notice 112 builds upon this framework by introducing actionable rights and responsibilities.
Future legislative actions are expected to:
- Introduce gender-neutral pay systems
- Expand access to pay comparison for work of equal value
- Mandate organizational-level reporting and Joint Pay Assessments
The risks of non-compliance
Once full transposition occurs, enforcement mechanisms in Malta will likely include:
- Fines and penalties for failure to disclose or report
- Public scrutiny via pay registry platforms
- Shift in burden of proof in discrimination cases
Malta’s proposed EU Directive legislation
Legal Notice 112 of 2025 introduces:
- Mandatory salary range disclosures pre-employment
- Employee rights to request individual and comparable pay data
- Employer obligations to respond within two months
Further legislation is expected to bring Malta into full compliance with the EUPTD by the June 7, 2026 deadline.
How Trusaic helps employers comply with Malta requirements
1. Comply – Use RAPTR™ to complete required reporting by compliance deadlines.
Stay ahead of evolving regulations with Trusaic’s Regulatory Pay Transparency Reporting™ solution, designed to help you determine applicability, meet deadlines, and submit compliant reports across EU jurisdictions with the click of a button.
Our Pay Equity Software Suite ensures your pay systems are legally defensible, gender-neutral, and future-proof — automating complex reporting and enabling GDPR-compliant data sharing through certified integrations with major HCM platforms.
2. Correct – Use PayParity® to understand, explain and resolve pay disparities.
Use PayParity to identify, explain, and resolve pay disparities across gender, race, age, and more. Whether you’re conducting proactive assessments or responding to compliance triggers like the EU Directive’s Joint Pay Assessment requirement, PayParity delivers defensible, data-driven insights. Our Remediation Optimization Spend Agent (R.O.S.A.) works as PayParity’s AI remediation partner to ensure you lower your pay gap below 5% while maximizing the ROI of your remediation budget.
3. Communicate – Use the Pay Equity Product Suite to communicate narratives and share salary ranges with confidence.
Comply confidently with the EU Directive’s pay range transparency mandates using Trusaic’s Salary Range Finder, which provides data-driven guidance for equitable pay ranges that can be shared with candidates and employees.
Our Pay Transparency Agent answers reporting questions instantly, and our Communications Agent crafts context-specific narratives — in any language — to support your public disclosures and internal communications.
How to prepare to comply with the EU Directive
To get ahead of Malta’s upcoming compliance mandates, employers should:
- Audit recruitment practices to ensure initial pay disclosures are ready by August 2025
- Implement systems to fulfill employee pay data requests
- Begin aligning pay structures with equal pay principles
- Track evolving legislation to adapt compliance strategies accordingly
Trusaic is GDPR-compliant and supports multinational employers in meeting obligations under both the EU Pay Transparency Directive and the Corporate Sustainability Reporting Directive (CSRD).
FAQ
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What is Malta’s current status on implementing the EU Pay Transparency Directive?
Malta published Legal Notice 112 of 2025 on June 27, 2025, establishing its first legal obligations in line with the Directive. These provisions take effect on August 27, 2025, with further legislation expected before the June 2026 deadline.
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Are employers currently required to report gender pay gap metrics in Malta?
No. Legal Notice 112 does not include reporting obligations. However, future legislation is expected to introduce reporting requirements based on employer size.
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What are employers required to disclose starting August 27, 2025?
Employers must disclose initial pay or salary ranges to candidates before employment, and disclose collective agreement pay provisions where applicable. Employees can also request their pay and pay of same-job peers.
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Will Malta adopt the EUPTD’s Joint Pay Assessment requirement?
This requirement has not yet been transposed into Maltese law. It is expected to be included in future legislation before the June 2026 transposition deadline.
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What penalties can employers face for non-compliance?
Penalties have not yet been specified under Legal Notice 112, but enforcement measures will likely align with the Directive’s standards, including fines and a shift in burden of proof in discrimination cases.