The EU Pay Transparency Directive 2023/970 (the Directive) sets minimum standards to promote gender pay equity, which all EU Member States must transpose into national law by 7 June 2026.
Taking the form of a Directive, it establishes a common framework but allows Member States discretion in key areas, such as defining worker, job categorisation, sanctions, and exemptions for small employers. Member States may also choose to go beyond the minimum requirements by imposing stricter obligations.
For employers operating across multiple jurisdictions, understanding these local variations will be critical.
In this Insight, we summarise the Directive’s core standards, highlight what actions you should take as an employer, provide an update on implementation across Member States, and highlight early indications of national deviations.
Directive’s core standards
The Directive aims to create consistency in processes and standards to eliminate gender pay inequality through four key objectives:
- empower employees
- increase transparency
- improve public understanding
- enhance enforcement.
| Transparency for job applicants | All employers |
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| Transparency for employees | All employers |
|
| Access to pay criteria | All employers |
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| Gender pay gap reporting | Only mandatory for employers with 100 or more employees |
Reports must include:
Reporting duties start dates:
Reports must be available to employees, representatives and supervisory authorities. |
| Joint pay assessments | Only applies to employers who are required to produce gender pay gap reports |
If a gender pay gap of 5% or more is identified and cannot be justified by objective, gender-neutral criteria, employers must:
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| Enforcement and remedies | All employers |
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What does the directive mean for employers?
To comply with the EU Pay Transparency Directive, most employers will need to review and upgrade existing policies and processes. Key actions include:
- Remove pay confidentiality clauses from employment contracts and policies.
- Update recruitment practices:
- Ensure job adverts are gender-neutral and include pay details.
- Prohibit recruiters from asking candidates about current or past pay during selection.
- Define job structures and career paths:
- Clearly outline each role, its position within a career path, and what differentiates it from higher or lower roles.
- Implement objective job evaluation methods:
- Use structured, gender-neutral techniques to assign grades and compare roles across career paths using clear criteria.
- Establish salary bands for each job grade based on competitive market benchmarks.
- Draft a pay transparency policy that includes:
- Career paths, job grades, and salary bands.
- Criteria for pay setting and career progression.
- Employee rights to request their pay level and average pay by gender for comparable roles.
- Prepare for gender pay gap reporting:
- Check local headcount thresholds, as they may differ from the Directive.
- Communicate employee rights annually and encourage open dialogue on pay transparency.
Implementation update
Member state
Austria
Status
No progress yet.
Comment
The Directive is far more stringent than current requirements.
Belgium
Status
Partial implementation.
Comment
In January 2025 laws came into force that apply to public sector employers in the French speaking Community. Unlike the Directive there is no headcount threshold for unexplained pay gaps and makes no reference to joint pay assessments with employee representatives.
Bulgaria
Status
No progress yet.
Comment
No activity to report.
Croatia
Status
No progress yet.
Comment
No activity to report.
Cyprus
Status
Draft legislation imminent.
Comment
No clear indication as to when the draft legislation will be ready.
Czech Rep
Status
Partial implementation.
Comment
The three largest business associations have requested that the implementation be postponed for two years. The Ministry of Labour and Social Affairs has not responded to this formal request. Some progress has already been made, on 1 June 2025 the Labour Code was amended introducing a ban on pay secrecy clauses in employment contracts.
Denmark
Status
Draft legislation imminent.
Comment
No draft legislation has been released. New legislation will simply modify an already robust equal pay statutory framework.
Estonia
Status
Draft legislation imminent.
Comment
No draft legislation has been released. New legislation will simply modify an already robust equal pay statutory framework.
Finland
Status
Draft legislation imminent.
Comment
Draft legislation already published and mirrors the requirements of the Directive and upgrades existing equal pay frameworks (existing pay survey requirements for employers with 30 or more employees are likely to remain) closely.
France
Status
Draft legislation imminent.
Comment
No draft legislation has been released. New legislation will simply modify an already robust equal pay statutory framework.
Germany
Status
Draft legislation imminent.
Comment
Preparations are under way to update the local Pay Transparency Act, no date issued on when this will be published.
Greece
Status
No progress yet.
Comment
No activity reported yet.
Hungary
Status
No progress yet.
Comment
No activity reported yet.
Ireland
Status
Draft legislation released.
Comment
Ireland has already worked on its pay gap reporting laws which apply to employers with 50 or more employees. To implement the other requirements of the Directive will require an overhaul of current regulations before 7 June 2026.
Italy
Status
No progress yet.
Comment
No activity yet. Existing regulations require gender pay reporting every two years for employers with 50 or more employees (this threshold is likely to remain).
Latvia
Status
No progress yet.
Comment
No activity reported yet and current pay reporting only applies to public sector employers (however laws around pay transparency in job ads already exists).
Lithuania
Status
Draft legislation released.
Comment
Draft legislation was published in May 2025. Existing legislation already requires reporting from employers with 20 or more employees and corrective action is required for gender pay gaps of more than 5%.
Luxembourg
Status
No progress yet.
Comment
No activity yet although draft legislation is due to be published before the end of the year.
Malta
Status
Partial implementation.
Comment
Legislation went live on 27 August 2025 implementing some of the standards (namely disclosing pay rates to candidates) – further legislation will follow ahead of the 7 June 2026 deadline.
Netherlands
Status
Draft legislation released.
Comment
Despite having released draft legislation in March 2025 which closes follows the Directive with few deviations the government has recently announced that the 7 June 2026 implementation deadline is no longer feasible and is looking to push out to the 1 January 2027.
Poland
Status
Partial implementation.
Comment
A partial roll out of the Directive came as a result of the Act of 4 June 2025 which updated the Labour Code and requires employers to disclose initial pay rates to candidates, prohibits enquiries about current and past remuneration and ensures gender neutrality in adverts. The Act comes into effect on 24 December 2025 and further legislation will follow.
Portugal
Status
No progress yet.
Comment
No activity to report, although there is a working party and CITE (national equality body) is working on employer tools to assist with evaluation etc.
Romania
Status
Draft legislation released.
Comment
Draft legislation is timetabled for Autumn 2025, nothing has been published to date.
Slovakia
Status
Draft legislation released.
Comment
The Act on the Application of the Principle of Equal Pay for Men and Women for Equal Work or Work of Equal Value was released in October and closely follows the standards set out in the Directive.
Slovenia
Status
Draft legislation released.
Comment
No draft legislation yet. In December 2024 a national awareness campaign was initiated with an aim to roll out guidelines, training and methodology to help employers evaluate roles without gender bias.
Spain
Status
Draft legislation released.
Comment
No details have emerged on the draft legislation; however, Spain has already introduced a gender pay register requirement for all employers and a gender pay audit for employers with 50 employees or more.
Sweden
Status
Draft legislation released.
Comment
New laws will build on an already robust local framework of standards and will attempt to maintain much of the existing reporting requirements with some additional tweaks (current thresholds require pay reporting for employers with 10 or more employees). It is likely that the threshold for transparent pay progression criteria will apply to all employers (not restricted to employers with 50 or more employees as per the Directive).
If you have any questions or need further assistance please get in touch with your usual Crowe contact or Stuart Buglass.
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Global EOR terminations often expose companies to costly legal and compliance risks.
A civility policy fosters respectful behaviour, manages complex legal risks, and builds inclusive, high-performing workplace cultures.
Establishing a subsidiary offers greater operational control, significant long-term cost savings, and enhanced legal and compliance certainty.