As the deadline looms for countries to implement the EU Pay Transparency Directive (the "Directive") in June 2026, we have set out below the most recent country developments and some key points to note for the two jurisdictions likely to bring legislation into force in June 2026 (Italy and Slovakia).

COUNTRIES LIKELY TO IMPLEMENT THE DIRECTIVE IN FULL BY JUNE 2026

1. Italy

The Italian Council of Ministers gave final approval to its implementing decree on 30 April 2026, though the official text is yet to be published and the final version may still differ. Notable Italy-specific features include:

Definition of "equal work" and "work of equal value": Employers may rely on applicable national collective bargaining agreement (NCBA) frameworks, supplementary bargaining, or legislation when defining these concepts.

Narrow definition of "pay": Only fixed, continuous remuneration elements under the NCBA are captured — discretionary or temporary pay is excluded. Businesses should consider carefully whether to go further in Italy and align their approach in Italy with the broader definition in the Directive.

Pay information requests: Employees may only submit a pay information request once per year.

Gender pay gap reporting: Employers have 60 days to respond to clarification requests from employees, their representatives, the Labour Inspectorate, or equality bodies, and to address any unjustified pay discrimination identified.

2. Slovakia

Slovakia's implementing legislation is broadly in line with the EU Pay Transparency Directive and, once signed by the President, will come into force on 7 June 2026. 

However, a notable point of the implementing Act is the timeline for employees' rights to request pay information is staggered: 

The right to request information about an employee's own individual level of remuneration becomes available immediately upon the Act entering into force on 7 June 2026.

However, the right to request gender-disaggregated average remuneration data for a category of employees performing the same work or work of equal value is subject to a transitional provision. As the Act stipulates that employers shall provide this information for the first time "in respect of the year 2027," employees would only be able to exercise this right from 1 January 2028 at the earliest.

Existing employers should also note that the Slovak Act requires them to have a functioning pay structure capable of assessing work of equal value in place by 31 July 2026.

RECENT UPDATES AND TIMESCALES FOR OTHER COUNTRIES

Poland

Poland is unlikely to meet the 7 June 2026 transposition deadline. A six-month grace period within the draft bill means that even when the legislation is passed, pay transparency and equal pay rules are not expected to come into force until January–March 2027. Notable features of the Polish legislation include:

Employee pay information requests: All employers — including those with fewer than 50 employees — must respond to pay information requests within 30 days (shorter than the two-month period permitted under the Directive), based on gross pay received over the preceding 12-month rolling period. Employers who were planning to respond to right to information requests using the prior calendar year’s data may need a different approach for Poland unless this aspect is amended in subsequent draft legislation. 

Gender pay gap reporting: Reports, broken down by employee category, must be provided to employees and trade unions by 31 March each year, and to the National Labour Inspectorate and equality body within 30 days of a request.

Joint remuneration assessments: Employers have 10 months (extended from 8) to take effective remedial action following a joint pay assessment.

Spain

Spain is still in the early stages of implementation. A public consultation was published on 24 April 2026 and closed on 8 May 2026. Formal legislation will be drafted following the conclusion of that consultation process, meaning Spain is set to miss the 7 June 2026 transposition deadline.

Estonia

Estonia intends to adopt certain elements of the EU Pay Transparency Directive, including a requirement to include salary ranges in job advertisements, a prohibition on asking candidates about their prior salary, and a ban on salary secrecy clauses, although the timescale is unclear. Businesses operating in Estonia should be aware that whilst full compliance with the Directive may not be required, these targeted measures will still require attention.

Latvia

A draft law was published on 26 March 2026 and is currently undergoing public consultation. Following this, it will require approval by the Cabinet of Ministers before being adopted by the government, so it will not meet the June 2026 implementation date.

Luxembourg

The Luxembourg government recently launched a consultation within the Ministry of Labour under the form of a preliminary draft bill for the implementation of the EU PTD – but no official draft bill has been filed with the Chamber of Deputies yet, meaning that it will not meet the June 2026 implementation date. 

What This Means for You

These developments underscore that a uniform, "one size fits all" approach to the EU Pay Transparency Directive compliance across European operations may not be practicable. Country-specific nuances, particularly around definitions of pay, timelines, and reporting mechanics, will require careful consideration.

Your Contacts

At Deloitte, we understand that navigating the demands and complexities of pay equity and transparency can be daunting. Our proposition is designed to help you overcome this challenge and achieve your goals. Our aim is to enable you to pay employees equitably and help you demonstrate that you are doing so.

With our deep multi-disciplinary expertise in reward, employment law, technology & analytics, and behaviour change, we are well-placed to be your trusted partner on this journey. Get in touch to discuss your challenges and needs.

Kathryn Dooks, Partner, Deloitte Legal, 020 7303 2894

Deepinder Lamba, Partner, Deloitte Global Employer Services, 020 7007 2689

Note: The information provided is for general informational purposes only and may not be complete or up-to-date. Do not rely on this information without seeking professional advice. Deloitte LLP accepts no liability for any loss occasioned by any person acting or refraining from action as a result of this content