A comprehensive guide to the EU Pay Transparency Directive—navigate national transposition updates, understand key compliance duties, and turn legislative changes into an actionable strategy.
Anja Fordon
Senior Content Marketing Manager
Workday
The EU Pay Transparency Directive introduces new requirements concerning pay transparency, reporting and equal-pay enforcement. Its practical effect will depend on how Member States transpose the Directive into national law. This guide brings together points and national updates we are looking out for. You can navigate to the section most relevant to you using the menu on the left.
This is a living guide. It will be updated as national legislation, implementing measures and official guidance emerge. It is designed to distinguish what the Directive requires at EU level from what is confirmed, proposed or still unresolved locally.
Key takeaway: The Directive establishes a common direction of travel, but national transposition determines when and how many obligations apply in practice. Employers should prepare now without treating draft measures as settled law.
No. The Directive applies to EU Member States, not the UK. A UK-based or other non-EU company registered in an EU Member State may need to comply with that Member State’s implementing legislation where it has employees working in that Member State or employees whose employment contracts are governed by that Member State’s law.
For reporting, the relevant headcount should be the number of employees working in the Member State and meeting the applicable threshold. The Directive sets reporting thresholds that begin with employers of 150 or more workers in 2027 and extend to employers of 100 or more workers in 2031. National law may set a lower threshold.
Employer action: You can map workforce and employing-entity arrangements by Member State. A group’s headquarters location is not, by itself, sufficient to determine applicable local obligations.
A delayed transposition does not automatically give rise to a Directive-based claim against an employer. Until a Member State implements the Directive through national legislation, the relevant obligations do not apply to employers under that national framework. A worker may, in certain circumstances, seek compensation from the Member State for insufficient or delayed transposition; this is distinct from a claim against an employer based directly on the untransposed Directive. See this site for more information.
The European Commission may take action against a Member State that does not meet its implementation obligations. For employers, the central practical point is that the timing and content of enforceable duties remain tied to national legislation.
You can use official EU sources as the starting point. The European Commission maintains an overview of national transposition status here, while EUR-Lex can be searched for national measures.
Employers should validate material changes against published local legislation, official guidance and local legal counsel.
Watch this space: Member States may choose earlier national deadlines. The Directive’s transposition deadline was 7 June 2026, but national implementation dates and transitional arrangements are not uniform.
No. Articles 5 to 8 of the Directive are not subject to the reporting thresholds. These provisions follow the Directive’s general scope and apply to workers with an employment contract; Article 5 also covers job applicants. Member States cannot narrow that scope below the Directive’s baseline, although Article 6 permits an exemption for employers with fewer than 50 workers from the requirement concerning pay-progression information.
This matters because an employer that is below a reporting threshold may still need processes for candidate pay information, pay-setting transparency and worker information requests once national law takes effect.
Below are a few suggestions to help you prepare for the local implementation of the Directive. Naturally, your tailored preparation plan should be developed in consultation with relevant stakeholders, including your legal counsel.
The Directive’s requirements make job categorisation central. Employers should identify how roles are evaluated, how work of equal value is assessed, and whether the criteria are objective and gender-neutral. This is a governance exercise as much as a data exercise: a pay gap can only be interpreted credibly when the underlying comparison groups are sound.
Reporting will require processed statistics drawn from compensation data. Employers should establish a reliable view of base pay, relevant pay components, worker categories, legal entities and local populations. The precise metrics and inclusion rules will be shaped by national law. Employers should validate country-specific pay definitions, remuneration components and reporting requirements against applicable legislation and official guidance.
Articles 5 to 8 are not limited to large employers. Employers should therefore define ownership, workflow, review and privacy safeguards for worker requests about individual pay and average pay levels for comparable work. National rules may set important operational detail, including how employers protect identifiable individuals’ pay information.
Where a difference is identified, employers will need to assess whether it can be explained by objective, gender-neutral criteria and whether corrective action is required. Keep a clear distinction between an analytical explanation and a legally sufficient justification; local counsel can help review the latter.
Map which entity, function or agreement determines pay components. This will help employers assess the relevance of the single-source principle, anticipate possible cross-entity questions and make local reporting decisions on a better factual basis.
The Directive includes mechanisms addressing differences that cannot be justified by objective, gender-neutral criteria. HR, legal, finance, data and employee-relations teams should agree how they will investigate gaps, consult representative bodies where required, document decisions and implement remediation.
Employer action: You can build a country-by-country readiness plan, but you may use a common internal standard for job evaluation, data governance and decision documentation. Local law should determine compliance; a coherent operating model makes compliance manageable.
The EU implementation deadline expired on 7 June 2026. However, many Member States have not fully transposed the Directive into their national laws yet. We have classified the following Member States in 5 categories (based on their situation as of the end of July 2026, except where a more recent date is indicated):
Germany has not yet published a formal transposition bill. An expert commission on low-bureaucracy implementation began work in July 2025 and issued recommendations in October 2025. Its report is not draft legislation; it is an input for the legislature and contains divergent views on some questions. The commission recommended staying close to the Directive while introducing detailed rules.
A formal legislative draft is still pending but expected within the current calendar year, likely after the parliament's summer break in September. The implementation of the new German Pay Transparency Act is expected in early 2027.. These are expected timings, not enacted legal dates.
Depending on the eventual timing and content of legislation, reporting duties and the duty to respond to employee information requests could be deferred until 2028.
Germany’s existing Pay Transparency Act (Entgelttransparenzgesetz) remains less extensive than the Directive. Major changes are anticipated, including a broader scope for information rights (e.g. for job applicants or for employees of small companies), more detailed reporting, potential representative action and new penalties (including fines).
The French Government circulated an initial draft to social partners for consultation on 6 March 2026. A substantially revised version was subsequently provided to trade unions between 4 and 5 June 2026. The bill transposing this directive into French law was presented at the Council of Ministers on September 10, 2026. This marks the beginning of the parliamentary process.
The Minister of Labour has also indicated that he “hopes” the legislation will be finally adopted before the presidential election scheduled for May 2027. As per the draft bill, the requirement to report the gender pay-gap indicator would apply no later than three years after promulgation for employers with 100 to 149 employees, and no later than six years after promulgation for employers with 50 to 99 employees. Employees' individual right to receive information would become effective once the collective agreement or unilateral decision establishing the categories of employees considered to perform work of equal value enters into force — and, in any event, no later than the date set for reporting that same gender pay-gap indicator for the employer's category.
Below are a few key measures (this is not an exhaustive list of all provisions set out in the draft bill, but rather a highlight of local specificities, which could be subject to change before enactment):
No Austrian transposition bill has been published. There is no indication of when a public draft may be expected.
No national implementation dates are confirmed.
Current Austrian law requires income reports from employers above the existing 150-employee threshold. The Directive will bring reporting within scope from 100 employees (or lower).
Belgium has not adopted a comprehensive transposition framework. Belgium’s multi-layered federal, regional, community and collective-bargaining system makes implementation particularly complex and requires coordination across several legislative and regulatory layers.
No draft legislation has been formally introduced for the private sector.
On 1 June 2026, the federal government requested the European Commission to postpone the initiation of infringement proceedings for six months. The government also announced its intention to seek clarification from the Commission on a number of technical and practical aspects of the Directive in order to facilitate a workable implementation.
Progress has, however, already been made within certain parts of the Belgian public sector. Various legislative measures introducing pay transparency obligations for public sector employers have been adopted by the Communities and Regions:
Discussions are ongoing within the National Labour Council (NLC), which brings together representatives of employers' and workers' organisations. The NLC has examined whether certain aspects of the Directive could be incorporated into existing collective labour agreements. No formal opinion has been adopted to date and it remains uncertain whether a consensus position will be reached. To the extent that implementation cannot be achieved through collective bargaining, legislative intervention at federal level will be required.
Additionally, BE-MAGIC (Belgium – Modernisation and Adaptation of Gender-neutral Instruments of Classification aiming at providing tools and methodologies for gender-neutral job evaluation and classification systems. The project has now completed its analytical phase and entered its final implementation phase, following the publication of a policy paper containing recommendations for policymakers and social partners. Its mission is supposed to end in January 2027.
A draft bill has been published, but it has not advanced following consultation. The Ministry of Employment consulted on the bill from 26 February to 27 March 2026; subsequent progress has been affected by the election and a prolonged period without a sitting government.
The draft proposes entry into force on 1 January 2027. First reports would be due on 1 September 2028 for employers with at least 150 employees, based on 2027 data, and on 1 September 2031 for employers with 100 to 149 employees and certain employers with 50 to 99 employees, based on 2030 data.
Below are a few key measures (this is not an exhaustive list of all provisions set out in the draft bill, but rather a highlight of local specificities, which could be subject to change before enactment):
A government proposal is before Parliament. The proposal was submitted on 9 July 2026 to Parliament after consultation and is described as a minimum-level implementation with Finnish-specific clarifications and provisions.
The proposal is intended to enter into force on 1 January 2027. For employers with at least 150 employees, continuous underlying-data submission would begin with the first pay period beginning on or after that date, with the first category-level report due by 2 May 2028 (covering the 2027 calendar year). For employers with 100 to 149 employees, the obligation to submit underlying data would begin on 1 January 2030 and the first category-level report would be due by 2 May 2031 (covering the 2030 calendar year).
The Government’s summer legislative programme confirms that Heads of the Bill (initial policy outline or blueprint for the proposed law) are being prepared.
The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 (the “General Scheme”) was published in January 2025 as part of the pre-legislative process. The General Scheme proposes to transpose Article 5 of the Directive by amending existing legislation by:
Currently, the Employment Equality Act 1998 (as amended) (the “EEA”, currently in force) provides for employers with more than 50 employees to produce an annual Gender Pay Gap Report including mean/median pay differences, bonuses, and pay quartiles. The EEA does not fully align with the requirements of the EU PTD e.g. the information is not broken down by category of worker, does not provide for joint pay assessments, right to request information, etc.
Italy has completed transposition. Legislative Decree No. 96 of 7 May 2026 was published on 1 June 2026 and took effect on 7 June 2026. Some implementing ministerial decrees remain outstanding.
Reporting obligations as per the Decree begin by 7 June 2027 for employers with at least 150 employees and by 7 June 2031 for those with 100 to 149 employees.
Guidance on the assessment of “work of equal value” is expected by the end of 2026.
Below are a few key measures (this is not an exhaustive list of all provisions set out in the Decree, but rather a highlight of local specificities):
A transposition bill is before the House of Representatives, with supporting measures still in consultation. The updated bill was submitted on 21 May 2026. Draft secondary rules on reporting and pay definitions were published for consultation in June and July 2026 (a draft general administrative order and a draft ministerial regulation).
Employers with 150 or more employees would first report by 7 June 2028 on 2027 data; employers with 100 to 149 employees would first report by 7 June 2031 on 2030 data.
Below are a few key measures (this is not an exhaustive list of all provisions set out in the draft rules, but rather a highlight of local specificities, which could be subject to change before enactment):
Poland has partially transposed the Directive and has published a comprehensive draft bill. Recruitment transparency rules took effect on 24 December 2025. A second draft for the remaining provisions was published on 4 May 2026 and is under government consultation.
According to public statements made by officials from the Ministry of Labour,full implementation will likely not take effect until 2027. The draft retains Directive-based first reporting dates of 7 June 2027 for employers with at least 150 employees and 7 June 2031 for employers with 100 to 149 employees, but amendments are expected because the legislation did not take effect in 2026. Moreover, the draft bill indicates that pay gap reports shall be submitted electronically to the monitoring body by 31 March.
Below are a few key measures (this is not an exhaustive list but rather a highlight of local specificities).
The Act of 4 June 2025 (effective 24 December 2025) indicates that information on the salary package and relevant Collective Bargaining Agreement must be provided in either paper or electronic format at one of the following three stages:
With respect to the draft bill, please note that the final enacted legislation may differ significantly from the current draft bill, especially since a revised version of the draft legislation is likely to be prepared, although it is not yet known when this will occur:
Spain published a draft Royal Decree on 30 June 2026 proposing amendments to the existing Royal Decree 902/2020 on equal pay between women and men.It is not yet in force and would only partially transpose the Directive. Public consultation preceded the draft; it has not been approved by the Council of Ministers or published in the Official State Gazette.
On 3 August 2026, the Spanish Government published a formal draft Royal Decree amending Royal Decree 902/2020 on equal pay between women and men. It must now complete the remaining governmental review process before the final text can be approved by the Council of Ministers and published in the Spanish Official State Gazette.
Please note that the final enacted legislation may differ significantly from the current draft bill.
Below are a few key measures (this is not an exhaustive list of all provisions set out in the draft bill, but rather a highlight of local specificities):
Sweden is at a preliminary stage, despite an earlier legislative referral. A referral containing draft provisions was sent to the Council on Legislation on 15 January 2026, but the Government said in March that it did not then intend to submit an implementation bill. The Equality Ombudsman has been asked to continue preparatory work.
The Equality Ombudsman must report back by 1 November 2027. No parliamentary bill or enacted implementation date is confirmed. Under the proposed transitional provisions, the reporting obligations would apply for the first time in 2027 to employers with 150 or more employees and in 2031 to employers with 100–149 employees
Please note that the final enacted legislation may differ significantly from the current referral.
Below are a few key measures (this is not an exhaustive list of all provisions set out in the referral, but rather a highlight of local specificities):
This guide records our own interpretations and national updates as of the date above. It is not a substitute for advice on a specific workforce, pay structure or dispute.
Please note that the information provided here is for high-level informational purposes only and is not intended as legal advice. Organisations should always consult with their own legal counsel regarding any compliance-related matters and determine for themselves if the information provided here meets their business and compliance needs.
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