On 26 January 2026, Cyprus published draft legislation implementing the EU Pay Transparency Directive, meeting all core requirements whilst introducing enhanced provisions in several areas.

The law applies to all public and private sector employers and employees with contracts or employment relationships. The implementation is largely in line with the Directive, save as follows.

Key enhancements beyond the Directive:

• Small business support: Employers with fewer than 50 employees are exempt from pay progression obligations, with technical assistance and training provided to employers with fewer than 250 employees.
• Strengthened enforcement: There will be the potential for criminal sanctions for non-compliance including imprisonment up to six months or fines up to €10,000, with criminal liability extending to directors and officers of legal entities.
• Worker representatives: Workers' representatives means "workers' delegates or representatives" as provided by the pre-existing Cypriot Law on the Convention of Workers' Representatives (Ratification). If there are no workers' representatives within the meaning of that law, workers should be able to be represented by a representative of their choice.
• Pay: For purposes of Articles 8, 10 and 11, “pay” does not include elements such as payments in case of dismissal, lump sums upon retirement, or occupational pensions financed by employees' contributions on a voluntary basis. This implements the Directive's definition with clarification on exclusions for specific reporting purposes.
• Designated Authority: Specific powers will be assigned to the Administrative Commissioner alongside the Labour Relations Department as Monitoring Body.

The law will become effective upon publication in the Official Gazette, which is likely to happen in time for the 7 June deadline.

We had anticipated that France would publish its draft legislation at the end of January. However, this did not happen. Instead, on 21 January 2026 the French Minister of Labour Jean-Pierre Farandou confirmed the government’s intention to transpose the EU PTD this year, but he noted that the June 2026 deadline may not be met. Consultations with social partners were launched in Spring 2025 but were delayed by the fall of the Bayrou government and the time that was needed to set up the second Lecornu government.

The government intends that the draft bill should be published before June, with the intention of passing the legislation by the start of the new parliamentary session in September 2026 at the latest. 

On 15 January 2026, Minister for Gender Equality Nina Larsson made a referral to the Council on Legislation of the draft legislation. The legislation will be voted on by Parliament on 17 March 2026 and is due to come into force on 1 July 2026, subject to comments by the Council on Legislation and voting in Parliament.

Sweden's approach is more expansive than the minimum Directive requirements, particularly in applying obligations to smaller employers. This is because, in addition to the gender pay gap reporting (salary report), all employers must undertake a pay survey (Lönekartläggning) which is primarily an internal document; it is only submitted to the Equality Ombudsman in specific circumstances (e.g., when pay differences of 5%+ are not justified or remedied). It should be noted that although all employers are obliged to undertake the pay survey, only companies with 25+ employees are required to document it. ​

The Netherlands government published a revised draft bill in January 2026, following the conclusion of its consultation process. The revised draft bill rows back from some of the more controversial proposals in the original draft. 

The draft bill re-confirms the government’s intention to implement the Directive late, with the legislation entering into force on 1 January 2027. The first gender pay gap reporting will occur on 7 June 2028 (for calendar year 2027).

Key points to note from the latest draft legislation:

• Definition of employer: in the revised draft, this is no longer linked to the Dutch Works Councils Act definition of “enterprise” but instead will follow what is customary in practice – ie the party with whom the employee has entered into the employment contract or public law appointment. Reporting will therefore take place at employer level unless a parent company centrally determines remuneration policy and subsidiaries have no room to deviate; in such cases reporting may be done at group level.
• Thresholds for gender pay gap reporting: when counting the number of employees to determine the thresholds for gender pay gap reporting, the employer must include all hired staff working under the supervision and direction of the company (temporary agency workers).
• Worker representatives: An employer requires the Works Council’s consent for any proposed decision to establish, amend or withdraw (1) objective and gender‑neutral criteria underlying the grading and classification system, (2) classification into categories of workers performing equal work or work of equal value, (3) the manner in which unjustified pay differences between men and women will be remedied following pay reporting and (4) the joint pay assessment. Trade unions may also be involved through matters governed by collective bargaining agreements.
• Definition of pay: Only employer-wide costs not tracked at the individual level are excluded from the definition of “pay”, keeping reports standardized and comparable. Currently, there is no clarity on whether the employer is required to use paid actuals (i.e. from payroll data) or planned pay (e.g from HRIS). Guidance confirms that retention arrangements are expressly excluded, as they do not constitute remuneration owed for work performed.
• Temporary agency workers: Temporary agency workers supplied under the Labour Allocation by Intermediaries Act (in Dutch: Wet allocatie arbeidskrachten door intermediairs) should be counted in the pay data of the hiring company, not the staffing agency. Where temporary agency workers are used, the report must consist of two parts: one part relating to the hiring company's own workforce and the other part relating to the temporary agency workers.

The Belgian government had already published legislation covering the French and Dutch-speaking public sector in Belgium but in January there was a parliamentary proposal setting out a possible approach to transposition, requiring a proportionate transposition, making limited targeted updates where existing private-sector law already meets the Directive, and an extension of similar rules to federal public employment). No draft legislation has been published at this stage, so it is just a recommendation on how to proceed to implement the Directive for the private sector in Belgium. There is no immediate legal change, but it signifies political intent towards implementing the EU PTD in time for the 7 June deadline.

In early February, the Italian Council of Ministers approved a preliminary draft legislative decree. The draft will now be submitted to the Government for examination.

Key points to note:

• Definition of work of equal value: The role assigned to national collective bargaining is crucial, as it becomes the main reference point for defining categories of workers who are performing 'equal work' or 'work of equal value', with a presumption that if the categorisation used in the CBA is applied, it will meet the obligation of objectivity and gender neutrality. That said, professional classification systems adopted by the employer to determine remuneration are also permitted. It remains to be seen how these two approaches can be reconciled.
• Recruitment obligations: job advertisements and notices should set out the initial level of remuneration. There is no option to provide this in another way prior to interview.
• Some other aspects of the draft legislation do not appear to be in line with the provisions of the Directive but we have assumed that this is error and that these will be resolved in the final text.