Directive (EU) 2023/970 — the obligations, the reporting timetable, and where member state transposition actually got to after the 7 June 2026 deadline.
Member states were required to transpose the EU Pay Transparency Directive into national law by 7 June 2026. The European Commission confirmed that deadline held. Most member states did not meet it.
That has produced an awkward position for employers with EU headcount: the obligations are known, the direction is settled, and the compliance date has gone — but the national law that will actually bind you may not exist yet, and when it arrives it may differ from your neighbour’s. Waiting for certainty is not the same as doing nothing, and the two are easily confused.
Our view is that the pay architecture work required by this directive takes longer than the legislative gap. Building defensible job levelling, objective pay criteria, and clean pay data is 12–18 months of work in a large organisation. The countries that transpose late will not extend their compliance dates to match.
Position as at the 7 June 2026 deadline. This is the fastest-moving part of the picture — treat it as a snapshot and confirm current national status before acting.
| Status | Member states |
|---|---|
| Transposed | Italy (Legislative Decree 96/2026), Slovakia (Act 76/2026 Coll.), Lithuania (Law XV-969), Malta (Legal Notice 173/2026) |
| Partial, already binding | Poland (recruitment-stage rules in force since 24 December 2025), Belgium (public sector, from 1 January 2025), Czechia (salary-history and pay-secrecy bans in force) |
| Missed the deadline | France, Germany, Spain, Netherlands, Sweden, Ireland, Denmark, Finland, Portugal, Austria, Hungary, Luxembourg, Bulgaria, Cyprus, Latvia, Romania, Estonia, Greece, Croatia, Slovenia — no enacted law, or still in draft or consultation |
Compiled from public transposition trackers as at the June 2026 deadline. National positions are changing week to week; verify the current status in each country where you employ before relying on this. This page is information, not legal advice.
| Workers | First report | Thereafter |
|---|---|---|
| 250+ | 7 June 2027, on 2026 data | Annually |
| 150–249 | 7 June 2027 | Every three years |
| 100–149 | 7 June 2031 | Every three years |
Note the implication of the first row: the reporting period is 2026 data. That year is already more than half gone. Employers at 250+ workers are accruing the data they will have to publish now, whether or not their member state has transposed.
Everything below is required by the directive in every member state, is unaffected by how a given country drafts its national law, and takes longer than the legislative delay.
For UK-headquartered groups with EU populations, this runs alongside existing UK obligations rather than replacing them — see our London executive compensation page.
Member states had to transpose Directive (EU) 2023/970 into national law by 7 June 2026. The European Commission confirmed that the deadline remained unchanged. The majority of member states did not meet it.
As at the 7 June 2026 deadline, four member states had transposed in full: Italy (Legislative Decree 96/2026), Slovakia (Act 76/2026 Coll.), Lithuania (Law XV-969), and Malta (Legal Notice 173/2026). Poland, Belgium and Czechia had partial measures already binding. Around twenty member states — including France, Germany, Spain, the Netherlands and Ireland — had no enacted law or were still in draft or consultation. This changes frequently, so verify current national status.
The practical answer is yes. Employers with 250 or more workers report for the first time on 7 June 2027 using 2026 data — the data is being accrued now, regardless of when a member state legislates. The underlying work, particularly job levelling and equal-value job architecture, typically takes 12 to 18 months in a large organisation, which is longer than the transposition delay is likely to last.
Applicants must be informed of the initial pay or pay range for the position, either in the vacancy notice or before the interview. Separately, employers may not ask candidates about their pay history. Both are already in force in Poland.
Employers with 250 or more workers report from 7 June 2027 on 2026 data, and annually thereafter. Employers with 150 to 249 workers report from the same date and then every three years. Employers with 100 to 149 workers report for the first time on 7 June 2031, then every three years.
Yes. In alleged pay discrimination cases the burden of proof rests with the employer. Where an employer has not complied with its transparency obligations, it falls to the employer to demonstrate that no discrimination took place — which is why the underlying documentation matters more than the reporting itself.
The architecture work takes longer than the legislative gap. Tell us where your people sit and we’ll tell you what to start on.
Tell us what you’re working through and we’ll follow up directly.