Deadline passed - now what?
Read our previous article on Latvia's preparations for the EU Pay Transparency Directive here.
7 June 2026 was the deadline for all 27 EU Member States to bring Directive (EU) 2023/970 on pay transparency into national law. The intention was a single, enforceable framework to narrow the EU gender pay gap, currently around 12.7%.
Only four Member States transposed in full on time: Italy, Slovakia, Lithuania and Malta. The other 23 are still drafting or consulting. Infringement proceedings from the European Commission are widely expected, although as of late June 2026 no formal letters of notice had been published.
Core obligations
- Pay information before hiring. The starting salary or salary range must be disclosed either in the job advertisement or before the first interview. Asking candidates about their salary history is prohibited.
- Individual right to information. Employees may ask, once a year, for their own pay level and the average pay of colleagues doing comparable work, broken down by gender.
- Pay gap reporting. Mandatory from 100 employees. First deadline for 250+ employers: 7 June 2027 on 2026 payroll data. Employers with 150-249 report by the same date, then every three years. Employers with 100-149 start in 2031.
- Corrective measures. An unjustified gap above 5% in a given worker category must be addressed within six months of reporting, together with worker representatives.
- Reversal of the burden of proof. Once an employee shows facts pointing to pay discrimination, the employer must disprove it.
Reporting deadlines by number of employees
First deadline: 7 June 2027 for 2026 payroll data.
Report by the same date and every three years thereafter.
Reporting starts in 2031.
Country snapshots
| Country | Status | Key dates | What matters for employers |
|---|---|---|---|
| Austria | No law. Contested draft. | Deadline missed. No timeline. | Ministry of Labour draft published, but employers criticise it for going beyond the Directive. Political deadlock - nothing imminent. |
| Belgium | Partial. | Public-sector decree in force since Jan 2025. Full federal law: late 2026 at the earliest. | Only the French Community public sector is covered so far. Belgium has asked the Commission for a six-month grace period. National collective agreements must be renegotiated first. |
| France | Draft in progress. | Target entry into force: 1 Jan 2027. | The existing Index de l'égalité professionnelle (50+ employees, since 2019) is a base to build on, not the finish line. Draft penalties of up to 1% of total payroll. |
| Germany | No law, but parts already bite. | Law: early 2027 at the earliest. Reporting and full right to information: likely June 2028. | Public-sector employers: the Directive applies directly from 8 June 2026. Private employers: the existing AGG and the 2017 Pay Transparency Act must be read in line with the Directive, and Article 157 TFEU applies directly between private parties. Federal Labour Court, Oct 2025 (8 AZR 300/24): one higher-paid colleague of the other gender is enough to raise a presumption of pay discrimination. |
| Italy | Fully transposed and in force. | Decree 96/2026 in force 7 June 2026. First reports by June 2027. | Faithful transposition, little gold-plating. National collective agreements are the reference point for equal value and give a rebuttable presumption of compliance. All employers, any size: salary ranges in job ads, no salary history questions, day-one right to written pay information (answer within two months). 50+: documented pay and progression criteria. 100+: pay gap reporting. |
| Netherlands | Draft close to the Directive text, but delayed. | Entry into force: 1 Jan 2027. | First reports for 150+ employers will use 2027 payroll data, filed June 2028; 100-149 employers report June 2031 on 2030 data. Salary ranges in postings and the salary history ban apply from 1 Jan 2027. |
| Poland | Partial. | Recruitment transparency in force since 24 Dec 2025. Full law not yet in Parliament. | Candidates must be told the starting pay or range, set on objective, gender-neutral criteria. Revised draft of the wider law published 29 Apr 2026. Open issues: gap calculation methodology, defensible pay criteria, and transparency versus data protection in small teams. |
| Spain | Not transposed, but domestic rules are already strict. | Public consultation closed 8 May 2026. No confirmed timeline. | Already in place: a mandatory pay register for all companies, pay audits and equality plans for 50+, and a duty to justify gaps of 25% or more. Courts must read existing rules (including Article 28 of the Workers' Statute) in line with the Directive. The Directive's 5% trigger will eventually replace the Spanish 25% threshold. |
Four things to do now
Review your job advertisements.
Pay ranges and the salary history ban are the most visible requirements and the first thing employees and regulators notice. Fix these in every jurisdiction, transposed or not.
Audit pay structures for gender neutrality.
Pay criteria must be objective, documented and free of gender bias. Organisations that have relied on negotiation, tenure or market benchmarking without a structured framework are most exposed. This is the work that takes time.
Build the right-to-information process.
Where the law is in force, employees can ask today. Answers must be accurate, on time, and must not expose other individuals' data.
Run the numbers on 2026 payroll data.
The first reporting cycle uses this year's data. Finding gaps early leaves time to explain or close them before they become public.
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