EU Pay Transparency Transposition: Czechia Restricts Pay Secrecy Ahead of Full Transposition

Takeaways

• While Czechia’s restrictions on employer-imposed pay secrecy are already in force, its broader implementing framework remains under development, with implementation currently targeted for 01.01.27 and certain obligations expected to be phased in from 2028 to 2031.
• Employers should review confidentiality provisions and related employment documentation now.
• The partial measure does not appear to “gold-plate” the EU Pay Transparency Directive materially, although the broader draft legislation should be monitored for additional country-specific requirements.

Related links

• EU Pay Transparency: Member States Near Transposition Finish Line 
• EU Pay Transparency + Uneven Member State Adoption: Four Points for Multinational Employers
• EU Pay Transparency Transposition: Poland Rolls Out Local Recruitment Requirements as Broader Framework Emerges

Article

Czechia has taken a different path from Poland’s approach to partial implementation of the EU Pay Transparency Directive 2023/970. Czechia’s recruitment transparency requirements are already in force while broader legislation remains under development.

Poland has adopted the full recruitment and reporting framework as its first step. Czechia’s initial partial transposition has taken the form of a single employee transparency protection: Employers may not prevent employees from disclosing information concerning their own compensation.

The pay-secrecy prohibition was not introduced as a stand-alone transposition measure. It was adopted as part of a broader Labour Code amendment, the “Flexibility Amendment.” The Amendment primarily increased flexibility in the termination of employment relationships and improved conditions for parents on maternity, paternity, or parental leave. By including the pay-secrecy ban in the Amendment, Czechia was able to achieve a partial transposition of the Directive before adopting comprehensive implementing legislation.

Czechia is one of four Member States (along with Poland, Belgium, and Estonia) where partial transposition measures are in force.

Pay Secrecy Restrictions Already in Force

Since June 1, 2025, when the Flexibility Amendment took effect, Czech law has prohibited provisions restricting employees from disclosing information about their own remuneration. Enforcing a prohibited pay-secrecy clause may be treated as an administrative offence, with hefty fines of up to CZK 400,000 (approximately EUR 16,000).

If they have not already done so, employers operating in Czechia should ensure that employment agreements, employee handbooks, confidentiality policies, and compensation-related documents do not contain provisions that improperly restrict employees from disclosing their own pay. Employers should review not only express pay-secrecy provisions, but also broader confidentiality language that could be interpreted as restricting employees from discussing their own remuneration.

The partial nature of the transposition, however, means that one aspect of the Directive is already enforceable as the broader framework remains pending.

Broader Framework in Development

Czechia has continued work on comprehensive legislation. A revised draft was submitted to the prime minister and Legislative Council on July 14, 2026, with broader implementation currently targeted for Jan. 1, 2027, and certain obligations are expected to be phased in from 2028 to 2031.

The broader framework is expected to affect:

• Recruitment practices; 
• Objective and gender-neutral pay-setting criteria; 
• Employee access to compensation information; and 
• Gender pay gap reporting.

Employers therefore should treat the prohibition on pay secrecy as only one component of the compliance framework that ultimately will apply.

Gold-Plating

The Czech pay-secrecy measure currently in force does not appear to materially exceed the Directive’s requirements.

The broader draft legislation, however, should be monitored for country-specific requirements as it moves through the legislative process. Because the draft remains subject to change, employers should distinguish between requirements already in force and proposed requirements.

As the legislation progresses, employers should evaluate whether the final Czech framework creates requirements that differ from the Directive or from the organization’s existing European compliance model.

What Employers Should Be Doing

If they have not already done so, employers in Czechia should first review employment agreements, policies, and other provisions that could be interpreted as restricting employees from discussing their own compensation.

Organizations should also use the period before full implementation to review job architecture, compensation methodology, recruiting practices, and internal pay data. Doing so will help employers prepare for the broader Czech framework without treating Czech compliance as a stand-alone exercise.

In particular, employers should already be assessing whether their existing remuneration systems meet the requirements for transparent and equal pay. Although the final wording of the transposition legislation is not yet available, the substantive core of the draft is unlikely to change significantly. The obligation to implement formal remuneration systems is expected to apply from Jan. 1, 2027. Larger employers in particular should begin preparing now rather than waiting until the last moment.

As with other Member States, employers also should consider how Czech requirements will fit within broader EU pay transparency compliance efforts while preserving the ability to accommodate country-specific requirements.

Employer Takeaway

Czechia illustrates another important feature of partial transposition. An employer may have a binding pay transparency obligation today even though the broader national implementation framework is still months away.

That makes obligation-by-obligation tracking increasingly important for multinational employers. A Member State may have enforceable pay transparency requirements even while its broader transposition legislation is pending.

Previously in this series: Poland demonstrates how recruitment requirements can take effect ahead of full transposition.

Watch for the next installment in our series on Belgium, where there is a different complication: Partial implementation at the regional level rather than a comprehensive national framework.

Please contact a Jackson Lewis attorney with any questions.