With less than a week to go until the deadline for implementation of the EU Pay Transparency Directive, we’ve seen a flurry of activity in the past week (summarised below). We’ve also set out in the attached table (below) the current status in each EU country and current implementation date where known.

Italy

Italy published the final draft of its legislation implementing the EU Pay Transparency Directive on 1 June. The final text is identical to the draft circulated in recent weeks, with no changes to the regulatory content. It will come into force on 7 June 2026. Please see our previous summary here: EU Pay Transparency Directive — Latest Country Updates April and May 2026, Kathryn Dooks, Deepinder Lamba

Netherlands: 

The Netherlands has published revised draft legislation implementing the EU Pay Transparency Directive, adopting a notably restrained "clean implementation" approach that transposes the Directive faithfully without adding unnecessary burdens on employers. It is to be implemented late, but no later than 1 January 2027. Key features include flexible rather than rigid deadlines, an exemption for employers with fewer than 50 employees from pay progression obligations, and stronger works council involvement including a formal consent right over pay evaluation processes. Notably, the government openly acknowledges that the June 2027 reporting deadline for larger employers will not be met, with the first report instead due in June 2028, citing the need for systems and infrastructure to be operational first. 

Bulgaria: 

Bulgaria has published draft legislation implementing the EU Pay Transparency Directive, to be implemented by 7 June 2026. It is positioned as a minimum implementation exercise — though in practice the draft is considerably more prescriptive than that framing suggests. While reporting thresholds broadly mirror the Directive and the phased timetable is largely followed, the draft introduces several notable areas of gold-plating: smaller employers with fewer than 50 employees are not exempted from pay progression transparency obligations, employers must automatically submit a formal justification to the enforcement body whenever a 5% pay gap is identified, and the legislation favours fixed deadlines over the Directive's more flexible "reasonable period" language. The Commission for Protection against Discrimination is also significantly expanded from a reactive complaints body into a proactive monitoring and oversight institution. 

Lithuania:

Lithuania passed legislation in May 2026 to implement the EU PTD on a split timeline. Most requirements take effect on 7 June 2026, but two significant provisions are delayed: employers have until 31 December 2026 to confirm or update their pay systems, and monthly data submissions to the National Social Insurance Authority (Sodra) — along with employee information rights (Right to Information) — do not begin until 1 January 2027. The delay to those latter provisions is structural rather than political, as employee information rights are dependent on data via the National Social Insurance Authority that cannot flow until the submission process is operational.

Germany

The Federal Cabinet had been expected to consider the draft implementation act for the first time on 27 May 2026, but that discussion did not take place as scheduled. It is now anticipated that the Cabinet will address the draft in June 2026, following which publication of the draft is expected around 20^th June.

Greece

Greece's Ministry of Labour and Social Security has developed a draft law transposing the Directive although the text has not yet been published. This follows a substantial consultation process in which over 65 proposals from social partners were incorporated into the text. The draft broadly follows the Directive's reporting thresholds and phased timetable — employers with 250 or more employees must report annually, those with 150–249 employees every three years, and those with 100–149 employees every three years from 2031 — and expressly exempts companies with fewer than 50 employees from pay progression transparency obligations. Where a gender pay gap of 5% or more is identified and not rectified within six months, a full pay review process is required. The publication of the draft bill is expected shortly, after which normal legislative procedure must follow. With this in mind, it is unlikely that Greece will meet the 7 June 2026 deadline. 

Summary

The attached table summarises the current position in each EU member state and likely timescale for implementation (where known). This table is correct as at 1 June 2026.

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