With the 7 June 2026 deadline for implementation of the EU Pay Transparency Directive deadline now passed, only 4 countries met the deadline: Italy, Lithuania, Malta and Slovakia, with Malta being a late and unexpected delivery.

Since the deadline, activity across EU member states continues at pace. This update summarises the key developments since our last briefing in early June 2026, including in Spain, Germany, the Netherlands, Romania, Slovakia, Greece and France. 

FINAL OR NEAR-FINAL LEGISLATION

Malta

On 5 June 2026, Malta implemented the remaining provisions of the Directive with immediate effect. Whilst existing Maltese law already required employers to disclose salary ranges to job applicants and pay information to employees on request, the new Regulations bring these requirements fully in line with the Directive. There may be a six-month grace period for employers to align their processes with the new legal requirements, though this is not yet clear under local law and remains a point we are continuing to monitor.

Key features of the Maltese implementation include:

• Pay information retention: A minimum five-year retention period applies to pay information data.
• Transparency for job candidates: Applicants must be provided with a salary or salary range before the conclusion of the recruitment process and may also request a written breakdown of the wage structure, including fixed and variable pay components.
• Right to information response times: Employers must respond to pay information requests within 8 days. Where information is inaccurate or incomplete, employers have a maximum of 45 days from the initial request to provide the correct information — failure to do so constitutes a criminal offence.
• Pay documentation: Employers with 25 or more workers must document the criteria used to determine workers' pay, pay levels, and pay progression.
• Worker representatives: Representatives are defined broadly to include union representatives, elected representatives, or any "other representative acting… in defence of that worker's interests," which may expand the scope for trade unions to secure greater representation in practice.
• Limitation period: Workers have three years in which to bring a claim for lost pay and compensation.
• Penalties: Fines range from EUR 2,500 to EUR 7,000, with amounts towards the higher end applicable for repeat infringements.

Slovakia

As per our previous update, Slovakia transposed the Pay Transparency Directive on 7 June 2026 — the Directive's transposition deadline. Following implementation, the Slovak Ministry of Labour has subsequently published a comprehensive 106-page guidance document covering job evaluation and pay structures, objective justification, and recruitment practices. Unlike much of the guidance published elsewhere in Europe, the document is a substantive attempt to explain what compliance looks like in practice, rather than a restatement of the legislation.

Greece

The draft bill transposing the EU Pay Transparency Directive has been approved by Parliament at Plenary Session. The next step is publication in the official Government Gazette, which will bring the law into force in Greece. We anticipate this will happen in the next few days. 

There are no material differences between the previous draft bill and the enacted legislation.

The only distinction concerns the entry into force of certain pay transparency obligations (Articles 8–20 and 27 of the Greek legislation). Specifically, the following obligations will enter into force on 1 November 2026:

• establishment of objective pay bands;
• right to information;
• pay transparency for job candidates;
• pay gap reporting;
• joint pay assessment;
• data protection in the context of the right to information;
• judicial protection and protection before the Labour Authorities; and
• prohibition of termination of employment due to the exercise of rights deriving from pay transparency obligations.

UPDATES ON DRAFT LEGISLATION

Spain

A draft of Spain's transposition has been "leaked" from the Spanish Ministry. It has not been officially published and should therefore be treated as for information purposes only. We anticipate that the text will be subject to a number of iterations before it becomes an official draft.

As expected, the draft amends the existing framework governing the Compensation Registry and Equality Plans. The text leaves considerable room for interpretation and contains notable gaps against the requirements of the Directive: there is no regulation of the information to candidates or any prohibition on asking applicants about their current compensation, and there is no reference to the 5% pay gap threshold. Further changes and amendments are therefore expected before this text advances further in the legislative process.

Germany

Germany's draft implementation act was scheduled for discussion at a Federal Cabinet meeting in June 2026. However, this was postponed until the August meeting. The Ministry has confirmed that the legislation will enter into force at the earliest in early 2027, and that pay reporting duties and the individual right to pay information will not become effective until June 2028.

Netherlands

The Netherlands has published a further draft Decree setting out rules on the reporting obligations for employers, the definition of wage concepts used for reporting, employees' right to information, and the publication of audit results. The draft has been published for public consultation and is open for response until 31 July 2026.

Romania

A group of MPs unexpectedly registered a draft bill in parliament implementing the Pay Transparency Directive with the Romanian Senate (Reg. No. B392/2026) — a notable development, coming just weeks before the parliamentary summer recess and following a period in which transposition had appeared to stall after the collapse of the Romanian government in early May. This is not a government-backed bill but simply one put together by a small group of MPs.

The registered text largely aligns with the minimalist draft originally published by the Ministry of Labour on 30 March 2026, though the bill remains at an early stage and may yet change significantly.

The bill has since received a negative advisory opinion from the Legislative Council. Whilst such an opinion does not block the legislative process, it contains extensive criticism identifying substantive deficiencies that are likely to necessitate significant revision. On 29 June 2026, the bill was assigned Senate registration number L445/2026, formally entering it into the legislative process as an active project before the Senate's standing committees.

The Senate has 45 days to debate, amend, and vote on the bill, calculated from 29 June 2026. That period is tolled during the parliamentary recess, which commenced on 1 July 2026, leaving 43 days remaining when parliament returns on 1 September 2026. The deadline for amendments has been set for 2 September 2026. Following a Senate vote or the expiry of those 43 days, the bill will proceed to the Chamber of Deputies. Taking into account the parliamentary calendar and the likelihood of further revision, the earliest Romania's bill could realistically become law is late October 2026.

France

On 5 June 2026, a new draft version of the implementing legislation was issued by the Government to the French Conseil d'État. An unofficial version has been circulated online and by the legal commentary publication Liaisons Sociales, though its authenticity has not been confirmed. Articles relating to the civil service were submitted to the CCFP on 18 June 2026 for consultation.

The Labour Minister is currently considering presenting the draft bill in July 2026 and holding a parliamentary debate from the end of 2026 onwards. The Minister announced on 29 June 2026 that the law implementing the Directive on pay transparency will most probably be adopted before the French presidential election in April/May 2027. The expected date of adoption of the law has therefore been postponed once again by the Government. It should also be noted that the Constitutional Court may be involved in the review of the law.

Bulgaria

Draft legislation was published at the end of May, with a consultation process open until 18 June. We anticipate there will be further revisions following the consultation process.

Belgium

Belgium has requested a six-month extension from the European Commission to transpose the Directive for the private sector, citing stalled negotiations with the National Labour Council.

Sweden

Sweden's position on transposition of the Directive remains uncertain. On 26 March 2026, Sweden announced that it was placing its transposition efforts on hold and would be seeking a postponement and renegotiation of the Directive at EU level.

However, on 8 June 2026, the Government instructed the Equality Ombudsman (DO) to continue preparatory measures for implementation, with a report from the DO due by 1 November 2027. Whilst the assignment document reiterates Sweden's intention to pursue postponement, the decision to continue preparatory work may signal a softening in the Government's stance.

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