The EU Pay Transparency Directive, formally Directive (EU) 2023/970, was adopted in April 2023 to strengthen the principle of equal pay for equal work. Member States have until 7 June 2026 to transpose it into national law. While no Member State has completed full implementation yet, several have taken significant steps forward, with some even going beyond the Directive’s minimum standards.

What the Directive Requires

The Directive introduces wide-ranging obligations for employers and new rights for employees. Employers with more than 100 workers must report regularly on gender pay gaps within their organisation. If a gap of 5% or more is found within any job category and cannot be objectively justified, the employer has six months to address it. If unresolved, a joint pay assessment must be carried out with employee representatives.

Employees also gain enhanced transparency rights. Salary ranges must be disclosed during recruitment, employers are prohibited from asking about a candidate’s salary history, and pay secrecy clauses are banned. Workers can request information on pay levels and criteria, including access to average pay data broken down by gender. These rights apply broadly, including to employers with fewer than 100 staff for some obligations.

Countries Already Moving Ahead

Belgium

Belgium’s French Community (Fédération Wallonie-Bruxelles) has gone the furthest so far. As of September 2024, it transposed the Directive for employers under its jurisdiction, particularly in the public sector. These rules exceed EU minimum requirements, mandating that job adverts must include salary ranges and tightening obligations around pay reporting and audits.

Finland

In May 2025, Finland published a draft proposal largely aligned with the Directive. It introduces new reporting obligations and transparency rules. Final legislation is expected before the end of 2025, which would make Finland one of the first countries to have a near-complete framework in place.

Ireland

Ireland has also moved forward with its General Scheme of the Equality Bill 2024. This draft law requires salary ranges in job advertisements and bans questions about applicants’ salary history. While additional provisions — such as detailed gender pay gap reporting — are still pending, the Bill signals clear progress toward transposition.

Malta

On 27 August 2025, Malta introduced regulations that partially transpose the Directive. These cover pay transparency during recruitment and grant employees the right to request pay data for comparable roles. Further measures, such as mandatory gender pay gap reporting and enforcement mechanisms, are expected in 2026.

Poland

Poland has passed legislation requiring salary ranges to be disclosed in job advertisements, addressing one of the Directive’s core obligations. Other elements, including systematic gender pay gap reporting, are still being prepared, with full compliance expected in late 2025.

Sweden

Sweden is considered one of the frontrunners. A draft law already published builds on the country’s existing pay audit system and even goes further than EU requirements by extending some obligations to smaller employers.

Why This Matters for Employers

For businesses, the Directive is more than a compliance exercise. It requires a fundamental shift in how pay is structured, documented and communicated. Employers should begin preparing now by:

• Auditing existing pay structures and identifying potential gaps.
• Reviewing recruitment processes to include salary ranges in job adverts.
• Removing or revising pay secrecy clauses.
• Setting up procedures to handle employee requests for pay data.
• Training HR teams and managers on transparency rights and obligations.

Even in countries where legislation is still in draft, early preparation reduces compliance risks and positions employers as leaders in pay fairness — a valuable advantage in a competitive labour market.