EU Pay Transparency: Member States Near Transposition Finish Line

Takeaways

• Transposition activity continues as EU Member States advance draft legislation and move toward adoption.
• Several countries are nearing implementation, making significant progress.
• Employers should prepare now despite varying timelines and country-specific implementation differences.

Related links

• EU Pay Transparency + Uneven Member State Adoption: Four Points for Multinational Employers
• EU Pay Transparency: Lessons for Employers from First Three Member States’ Legislation

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EU Member States’ uneven adoption and implementation of Directive (EU) 2023/970 on pay transparency is forcing employers operating in multiple EU jurisdictions to track national developments closely.

By the June 7, 2026, deadline only Italy, Lithuania, Malta, and Slovakia completed transposition of the EU Pay Transparency Directive. Greece recently finalized its transposition.

Importantly, while timelines have slipped, governments across Europe continue to advance draft legislation. In addition, public consultations have concluded in many jurisdictions, and a number of countries appear to be entering the final stages of their legislative processes.

For multinational employers, this means the compliance landscape continues to evolve rapidly.

Countries Nearing the Finish Line

While the timing of final adoption will vary from country to country, the reality is that many countries are expected to enact implementing legislation over the coming months (in most cases, by the end of 2026 or in 2027).

Jurisdictions making significant progress include:

• The Netherlands: Draft legislation has progressed through the advisory process, and implementation is expected to follow parliamentary consideration in January 2027.
• Ireland: A phased implementation approach is confirmed while work continues on comprehensive legislation.
• Denmark: Draft legislation has been published, with an anticipated implementation date in 2027.
• Finland: Draft legislation has been prepared but parliamentary timing has delayed final adoption.
• Czechia, Poland, Romania: Draft legislations have been published or are actively moving through national legislative procedures.

In France, the government has circulated updated draft legislation to unions and to the Conseil d’Etat (highest Administrative Court, also in charge of opining on draft legislation) early June, but the Labor Ministry announced June 29 that vote in Parliament was only to be expected before the Presidential election, in April/May 2027.

Other jurisdictions, including Belgium, Germany, Luxembourg, and Spain, continue to develop their legislative frameworks but remain at earlier stages of the process.

What Employers Should Be Doing

Although national implementation dates continue to shift, countries continue to move toward completion of their transpositions. The core principles established by the Directive include pay transparency during recruitment, restrictions on salary history inquiries, expanded employee information rights, gender pay gap reporting, and strengthened equal pay enforcement. These principles will inevitably become part of employment law across all EU Member States, albeit with important country-specific variations.

Many governments are also taking advantage of the flexibility afforded by the Directive to tailor implementation to existing domestic legal frameworks. As a result, employers should expect differences in areas such as:

• Reporting thresholds and implementation timelines;
• Enforcement mechanisms and penalties;
• Interaction with existing equal pay and pay reporting obligations;
• Employee consultation requirements; and
• Procedural rules governing pay assessments and remediation.

These national differences will be particularly important for employers operating across multiple European jurisdictions.

Upcoming Country-by-Country Series

Stay tuned for our upcoming series of country-focused updates examining the latest developments in key Member States. Each article will explore the status of national legislation, highlight significant departures from the Directive’s minimum requirements, and identify practical considerations for multinational employers.

Employers with operations across Europe should continue preparing for compliance, rather than waiting for national legislation to be finalized. Reviewing pay structures, compensation practices, recruitment processes, and pay reporting capabilities now will place organizations in a stronger position as Member States complete implementation throughout the remainder of 2026 and into 2027.

Please contact a Jackson Lewis attorney with any questions.