EU Pay Transparency Directive – Latest Country Updates as at 12 October 2026

With the 7 June 2026 deadline for implementation of the EU Pay Transparency Directive now passed, only 4 countries met the deadline: Italy, Lithuania, Malta and Slovakia, with Greece finalising its legislation shortly afterwards with a 1 November 2026 effective date and Estonia partially implementing some aspects of the Directive in July.

Since our last briefing in early September 2026 activity across EU member states continues at pace. This update summarises the key developments since early September in Spain, Finland, the Czech Republic, Denmark, Bulgaria, Croatia, France and the Netherlands.

UPDATES ON DRAFT LEGISLATION

Spain

We previously reported that a draft bill had been published in Spain and that we anticipated a quick implementation, potentially in October. Since then the Spanish government has called a general election and so parliamentary proceedings have been suspended.  That said, it is possible that the legislation may still be passed in the coming weeks, so companies are advised to keep a watching brief on the progress of this legislation and we will continue to provide updates.

Finland

Finland's Incomes Register has published guidance on pay transparency reporting. The bill to implement the Directive is still under consideration by Parliament, during which time it may be amended, but remains scheduled to take effect on 1 January 2027. The key points in the guidance on pay transparency reporting are:

• Gender pay gap formula: The gender pay gap must be reported using the following formula: average pay of women ÷ average pay of men × 100.
• Reporting deadlines: The first gender pay gap report would be due on 2 May 2028 for employers with 150–249 employees and for employers with 250 or more employees, and on 2 May 2031 for employers with 100–149 employees.

Czech Republic

The Czech Government approved a draft of the implementing legislation on 31 August 2026. The draft will now proceed through the legislative process, with most provisions expected to take effect on 1 January 2027, subject to parliamentary approval.

• Likely implementation date: The implementation is expected to be phased in: core remuneration system and recruitment transparency obligations from 2027; employee information rights, pay gap reporting and remuneration assessments generally from 2028; and certain rules concerning employers with 100–149 employees and agency workers from 2031.
• Approach of the Czech government: The Ministry of Labour and Social Affairs has presented the transposition as largely minimalist. Further details, including calculation methodologies, reporting forms and employer headcount calculations, are expected to be specified in implementing legislation tailored to the Czech legal framework.
• Pay information request: Employees should be entitled to request pay information only once per calendar year. Specific safeguards are proposed where disclosure could identify another employee's remuneration, including the possibility of providing the information through a trade union.
• Minimum remuneration information: Information on minimum remuneration and related benefits should be provided to job applicants no later than before the conclusion of the employment contract. Whether this timing fully complies with the Directive remains under discussion.
• Agency workers: Specific rules are proposed for agency workers. These include cooperation and information-sharing obligations between employment agencies and user undertakings, the user undertaking's involvement in determining the remuneration structure, and the inclusion of temporarily assigned agency workers in the user undertaking's pay gap reporting from 1 January 2031.

Denmark

On 8 October 2026, Denmark introduced a new draft bill to parliament to implement the Directive with the first Parliamentary reading scheduled for 22 October. An earlier bill was sent out for consultation in the spring of 2026, but lapsed due to the 2026 general election being called at the same time. The new bill is based on the previously introduced proposal, but elaborates on and clarifies how a wide range of obligations are to be understood. The bill is expected to be enacted on 1 March 2027 and clarifies that Denmark’s existing rules on gender-disaggregated pay statistics will continue to apply for the calendar year 2026 and the reporting year 2027.

Key features of the Danish implementation include:

Pay reporting requirement: The first pay report must be submitted by 1 September 2028 for companies with at least 250 employees, giving companies 15 months longer than the deadline set out in the Directive itself. For companies with between 50 and 149 employees, the first pay report must be submitted by 1 September 2031. Pay gap reporting only applies to employers with between 50 and 99 employees, where there are at least 8 employees of each gender in the same employee group as determined by the 6-digit DISCO code or equivalent classification system and employers in the agriculture, hunting, fishing and forestry sectors are excluded. For employers with 100+ hourly-paid employees, Statistics Denmark will send the employer a payroll statement for the previous calendar year on which to base the calculations. For employees who are not hourly paid, the employer must prepare the report itself. 

• Category of worker is defined according to the existing 6-digit DISCO code in Denmark or an equivalent classification system
• Pay reporting authority: Pay reports are to be submitted to the new Labour Market Institute for Equal Pay, with publication to take place at a company level. The establishment of the new Labour Market Institute for Equal Pay also means that the Danish Institute for Human Rights will lose its remit in the area of equal pay when the bill comes into force.
• Transparency for job candidates: The starting salary or salary range must be disclosed prior to the job interview. It will therefore not be a requirement for this information to appear in a job advertisement.
• Right to information: Employees will have the right to access their own pay data and the average salary broken down by gender for the category of employees performing the same work or work of equal value.
• Confidentiality safeguard: Where the disclosure of pay information could reveal an individual's salary, the information may only be provided to the employees' representative or the new Labour Market Institute for Equal Pay.
• Burden of proof and enforcement: Failure to comply with the new transparency requirements may in itself trigger a reversal of the burden of proof in an equal pay case. In other words, the employer must be able to demonstrate that equal pay obligations have been met. This is in addition to new compensation options, increased fines and amended limitation periods. Compliance is not merely an administrative matter - it can have a direct bearing on the outcome of legal proceedings.

Bulgaria

A bill to amend the Law on Protection against Discrimination, transposing the EU Pay Transparency Directive, was submitted to Parliament on 11 September 2026 and is now going through parliamentary committee review and voting. 

The legislation is broadly in line with the Directive but provides clarification regarding obligations towards agency workers:

• Entry into force: No general grace period applies, except that reporting and joint pay assessment obligations take effect on 7 June 2027 for employers with 150 or more employees, and on 7 June 2031 for employers with 100–149 employees.
• Definition of equal value: "Work of equal value" and "categories of workers" are both formally defined by reference to skills, effort, responsibility, and working conditions, measured against accepted standards for the quantity and quality of work and time spent.
• Right to pay information: Employees may request, in writing, directly or through their trade union or the Commission for Protection against Discrimination, information on their own pay and on average pay by gender for comparable categories of workers, with a response due within 2 months (up from 14 days in the previous draft); employees may also seek clarification if the information is inaccurate or incomplete. Employers must notify all employees annually, by 31 January, of this right and the relevant procedure.
• Confidentiality safeguard: Where disclosure could reveal an individual colleague's pay, the employer may restrict access and provide the information only to the trade union and/or the Commission on request.
• Pay secrecy clauses: Contractual or internal restrictions on employees sharing their own pay information are prohibited, but only insofar as the information is needed to exercise the right to equal pay.
• Gender-neutral job titles: Job titles must be gender-neutral in job adverts, unless an official occupational classification requires otherwise.[? 
• Reporting and consultation: Employers must carry out gender pay gap reporting following consultation with trade unions/employee representatives, providing a breakdown by category of worker and by basic and additional remuneration; where a gap cannot be objectively justified, employers must consult on corrective measures.
• Joint pay assessment: A joint pay assessment involving trade unions/employee representatives is triggered where an unjustified gender pay gap of 5% or more in a category of workers is not remedied within 6 months.
• Agency workers: The user (host) employer handles information and reporting duties for agency workers, who are also included in the host employer's headcount for reporting purposes.

Croatia

In Croatia, the Ministry of Labour has published a job evaluation methodology. Use of the methodology is not mandatory, but employers must in any event apply the Directive's four mandatory evaluation criteria (skills, responsibility, effort, and working conditions) when assessing the value of a job. Please note that the Croatian draft law transposing the Directive, through amendments to the existing Labour Act, has not yet been published. While the timing remains uncertain, publication of the draft law is expected within the next few weeks. 

France

On 10 September 2026, a revised draft bill transposing the EU Pay Transparency Directive was presented to the Conseil des Ministres, broadly following the earlier Conseil d'État draft. The bill now proceeds to Parliament, with the Government seeking adoption before the 2027 presidential election and the new regime envisaged from 1 January 2028, though the parliamentary timetable remains tight. The Senate is expected to examine the bill first; debate dates have not yet been confirmed.

Key features of the revised draft include:

• Transitional regime: The existing Professional Equality Index is retained throughout 2027, with the new seven-indicator regime applying from 2028; the non-regression principle ensures the new framework cannot reduce existing protections.
• Smaller employers: Employers with 50–99 employees are subject to all seven indicators but with simplified obligations; the previous "reasonable period" for initiating negotiations where an unjustified gap is identified has been removed, with no replacement deadline currently specified.
• Public procurement: The Public Procurement Code is amended, with potential exclusion from public procurement for non-compliance.
• Enforcement for larger employers: For companies with at least 100 employees, enforcement is strengthened: the administration may compel the opening of negotiations where an unjustified gap is found and the employer is inactive, and employee and SEC information requests now extend to all indicators.
• Sectoral negotiations: Sectoral negotiations are limited to establishing a categorisation method, rather than the categorisation itself.
• Outstanding detail: Many key parameters, including indicator definitions, deviation thresholds and justification criteria, remain subject to implementing decrees yet to be issued.

Netherlands

On 2 September, the Dutch government published a guidance note to accompany its draft legislation: Nota naar aanleiding van het verslag. 

The guidance note is in the form of responses to parliamentary questions regarding the draft Dutch legislation, so it is not binding law. It largely clarifies what was already in the draft law:

• Implementation timing: The Dutch government is still aiming for 1 January 2027 for implementation.
• GPG reporting: GPG reporting will start from 1 June 2028, relying on payroll data and the payroll tax declaration system.
• Definition of pay for RTI purposes: The RTI uses the same payroll definition of pay – taxable components would be included but certain untaxed benefits and reimbursements would be excluded (albeit that they remain relevant in the event of an equal pay claim).
• RTI and data protection: It confirms the approach that the RTI trumps data protection obligations in the event that there is only one man and one woman in a category of workers.
• Correction threshold: Unjustified differences in pay below 5% must still be corrected, albeit that a joint pay assessment is only triggered if there is an unjustified GPG of 5% or more.
• Job evaluation: Employers are required to undertake a job evaluation and classification.
• Agency workers: In respect of agency workers, the end user will report separately on their gender pay gap. However, agency workers will count to the employer’s own gender pay gap reporting threshold. RTI requests will be handled by the agency. Agency workers will be able to compare themselves to workers employed by the same agency, working for the same hirer and placed in the same category.

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