ALERT / SEPTEMBER 25, 2026

EU Pay Transparency Directive - Implementation Status

5 MIN READ

The European Union Pay Transparency Directive (Directive (EU) 2023/970, the “Directive”) aims to strengthen the principle of equal pay for equal work or work of equal value between women and men through enhanced pay transparency and enforcement measures. (See Lockton article here (opens a new window) for more details on the Directive and insights on how employers can effectively prepare for its implementation.)

EU Member States were required to transpose the Directive into national law by 7 June 2026. However, implementation remains uneven, with only a small number of countries having completed transposition by the deadline and many others still progressing draft legislation. The table below shows the status of transposition as of 23 September 2026.

EU Member State	Draft legislation published	Transposed	Implementation Status
Austria	✖	✖	An internal draft law was submitted by the Labor Minister for government political coordination on 6 June 2026 but has yet to be published.
Belgium	✖	✖	No draft legislation has been published for implementation on a national level.
Bulgaria	✔	✖	A revised draft law was submitted to the National Assembly on 11 September 2026.
Croatia	✖	✖	No draft legislation has been published.
Cyprus	✔	✖	A revised draft law was published on 26 January 2026.
Czechia	✔	✖	A revised draft law was published on 4 September 2026. The targeted implementation date is 1 January 2027.
Denmark	✔	✖	A draft law was published on 26 February 2026. The targeted implementation date is 1 January 2027.
Estonia	✔	Partially transposed	Amendments to the Employment Contracts Act to transpose certain provisions (mostly pre-employment) under the Directive took effect on 13 July 2026. Further legislative measures will be required for full transposition.
Finland	✔	✖	A revised draft law was published on 9 July 2026. The targeted implementation date is 1 January 2027.
France	✔	✖	A revised draft law was submitted to the Council of Ministers on 10 September 2026.
Germany	✖	✖	A draft law has been prepared but has yet to be published.
Greece	✔	Fully transposed	Law 5316/2026 entered into force on 6 July 2026. However, most employer obligations will only take effect from 1 November 2026.
Hungary	✖	✖	No draft legislation has been published.
Ireland	✔	✖	A draft law to transpose pre-employment provisions under the Directive was published on 15 January 2025. Further legislative measures will be required for full transposition.
Italy	✔	Fully transposed	Legislative Decree No. 96/2026 entered into force on 7 June 2026.
Latvia	✔	✖	A draft law was published on 26 March 2026.
Lithuania	✔	Fully transposed	Law No. XV-969 was published in the Register of Legal Acts on 25 May 2026. Most provisions took effect on 7 June 2026, with pay reporting obligations to take effect from 1 January 2027.
Luxembourg	✖	✖	No draft legislation has been published.
Malta	✔	Fully transposed	Legal Notice 112 of 2025 entered into force on 27 August 2025 and partially transposed provisions under the Directive. Legal Notice 173 of 2026 entered into force on 5 June 2026 and transposed the remaining provisions under the Directive.
Netherlands	✔	✖	A revised draft law was published on 21 May 2026 and is undergoing the legislative process. The targeted implementation date is 1 January 2027.
Poland	✔	Partially transposed	Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026.
Portugal	✔	✖	A draft law was published on 5 August 2026.
Romania	✔	✖	A revised draft law was submitted to the Senate on 17 June 2026.
Slovakia	✔	Fully transposed	The Equal Pay Act entered into force on 7 June 2026.
Slovenia	✖	✖	An internal draft law was submitted by the Ministry of Labor to the Economic and Social Council in February 2026 but has yet to be published.
Spain	✔	✖	A draft law was published on 3 August 2026.
Sweden	✔	✖	A revised draft law was published on 15 January 2026. However, on 26 March 2026, the government announced that it was seeking postponement of the implementation date and renegotiation of the Directive.

How Lockton can help

Your Lockton Multinational Practice, People Solutions team can assist in reviewing your benefits strategy to align with Directive requirements. They can also help assess how employee benefits in the EU, such as retirement plans, healthcare and wellbeing benefits, fit into your pay transparency roadmap, as these benefits are considered part of “pay” under the Directive for reporting purposes.

Lockton’s Compensation Consulting team can also help employers prepare for, operationalize and sustain compliance with the Directive’s compensation-related requirements. This support may include assessing current pay practices, job architecture, salary structures and pay decision criteria; conducting pay gap and pay equity analyses; evaluating gender-neutral job descriptions and leveling frameworks; and developing practical roadmaps, governance processes, manager guidance and communications to support greater transparency across EU workforces.

Readiness assessments to identify gaps in pay transparency practices, compensation governance, reporting capabilities and supporting documentation.

Job architecture, career framework and salary structure reviews to support clear, consistent and defensible comparisons of work of equal value.

Pay gap, pay equity and compression analyses to help employers understand potential risk areas and prioritize remediation strategies.

Updates to hiring and pay administration practices, including starting pay guidelines, salary range communication, gender-neutral job descriptions and manager talking points.

Additional insights are available in Ius Laboris EU Pay Transparency Directive interactive transposition tracker here (opens a new window).

For more information, please contact