The centrepiece of the Directive is a requirement that all employers with more than 100 workers must regularly report detailed information regarding the organisation’s gender pay gap. If this reporting reveals a gap of 5% or more within any job category and the gap cannot be explained by objective and non-discriminatory factors, the employer has six months to eliminate the gap. If it fails to do so, the employer must engage in an extensive pay audit process (a ‘joint pay assessment’), with oversight by the employee representatives.

The Directive also gives employees and prospective employees a number of individual pay transparency rights. For example, it requires employers to include salary ranges during the hiring process; prohibits employers from asking about a job candidate’s salary history; and prohibits efforts by employers to prevent employees from sharing salary information. It also gives employees the right to demand disclosure of information on pay levels and pay criteria. This includes access to average pay data relating to comparators and broken down by gender. These individual rights are set to apply largely irrespective of headcount, and so will impact employers with less than 100 workers.

Member States were required to transpose the Directive by 7 June 2026. This map shows the current status of transposition across Europe.

Changes in transposition status

• Hungary: Changed from ‘no activity’ to ‘initial steps’. According to the Government’s autumn 2026 legislative programme, a law to transpose the Directive is planned for adoption in October 2026.
• Portugal: Changed from ‘initial steps’ to ‘draft’. On 5 August 2026, a draft government bill partially transposing the Pay Transparency Directive into Portuguese law was published for public consultation. The public consultation period ended on 25 August 2026.
• Spain: Changed from ‘initial steps’ to ‘draft’. The Spanish Government published a draft Royal Decree to transpose the Directive on 3 August 2026. The draft was open for consultation until 24 August 2026. We have published a detailed insight on the draft Royal Decree here.

Other noteworthy developments

• Bulgaria (draft): A draft Bill amending the Protection Against Discrimination Act was submitted to Parliament on 11 September 2026.
• Cyprus (draft): In a response to a parliamentary question concerning pay transparency, the Minister of Labour and Social Insurance has confirmed the draft law to transpose the Directive is expected to be submitted to the Council of Ministers in September 2026 and subsequently to the House of Representatives for enactment, with employers with 150 or more employees required to submit their first gender pay gap data by 7 June 2027. Employers with 100-149 employees will be required to submit their first gender pay gap data by 7 June 2031.
• Czech Republic (draft): On 31 August 2026, the Government made additional minor amendments to the draft transposing law. On 4 September 2026, an updated version of the draft law incorporating those changes was published and will now be submitted to the Chamber of Deputies, where it will proceed through the standard legislative process.
• France (draft): The draft law to transpose the Directive was amended a second time on 10 September 2026, prior to its transmission to the Parliament. While the overall transposition timeline remains uncertain, the objective remains to obtain a final vote before the presidential elections, which are scheduled for late April and early May 2027.
• Germany (initial steps): There have been some (unconfirmed) rumours that the cabinet is expected to approve the draft bill (Gesetzesentwurf) in one of the cabinet meetings in October 2026, thereby initiating the German legislative process.
• Italy (transposed): The Italian Minister of Labour, following consultation with the Italian Data Protection Authority, is expected to adopt ministerial decrees in September setting out further details regarding the reporting obligations under Article 9(4) of the Legislative Decree.
• Netherlands (draft): On 2 September 2026, the Government published its response to a parliamentary report together with a number of largely technical amendments to the transposing Bill. Furthermore, a procedural meeting of the Dutch House of Representatives took place on 8 September 2026. The plenary debate is currently scheduled for the second week of January 2027. In its 2 September response, the Government maintained that transposition by 1 January 2027 remained feasible. However, that timetable now appears uncertain given that the plenary debate is not scheduled to take place until the second week of January 2027.