The new law entered into force on 7 June 2026, the exact date of the Pay Transparency Directive’s transposition deadline. Slovakia’s government committed to transposing the Directive closely and faithfully, and the Equal Pay Act largely delivers on that commitment. But while there are no major surprises, the Act does contain some notable deviations and elements of gold-plating that multinational employers need to understand.  

In this article, we summarise some of the key features of Slovakia’s new framework that employers need to be aware of.  

• Same-sex equal pay claims are in scope: Slovakia has extended equal pay protections beyond male-female comparisons. Employees of the same sex can also bring claims when they perform the same work or work of equal value. 

• Pay reporting deadlines are specific and vary: Employers with 150 or more employees must submit their first reports by 7 June 2027 for the period from 1 August 2026 to 31 December 2026. Employers with 250 employees or more must report annually thereafter whereas employers with 150-249 employees must report every three years. Employers with 100–149 employees must submit their first reports by 7 June 2031 for the year 2030 and then every three years thereafter. After the first reports, employers must submit reports by 15 April in a reporting year. 

• Defined response windows: Employers have two months to respond to employees’ initial requests for individual pay information. Employers have 30 days to respond to employee requests for additional individual pay information and to questions regarding pay gap reports. 

• Penalties may be steeper than they first appear: Fines for failures to report range from EUR 4,000 to EUR 8,000, but the Labour Inspectorate’s broader sanctioning powers apply. 

• Pan-European compliance just got more complex: With Slovakia setting a 15 April reporting date and other Member States like Latvia and the Czech Republic proposing different timelines in draft legislation, multinational employers will need to manage diverging deadlines carefully. 

On many fronts, Slovakia has stayed close to the Pay Transparency Directive’s text. 

Definition of pay  

Slovakia defines ‘remuneration’ as basic wage plus any other monetary benefits or benefits in kind. Basic wage includes minimum wage, tariff salary, functional salary and rank salary. Although Slovakia’s transposing law uses different terms, its definition broadly aligns in practice with the Pay Transparency Directive’s definition of pay. 

Pay range disclosure  

Employers must provide applicants with the starting salary or its range. If remuneration is governed by a collective agreement, employers must also provide applicants with the relevant provisions of the collective agreement. This information must be provided at a sufficiently early stage to enable informed and transparent negotiation of pay, either before the job interview or before the conclusion of a contract with the employee. Employers do not need to include this information in the job advert but, if they do so, the information obligation is deemed to be fulfilled. 

Employee information rights 

Employees have the right to request and receive written information on average pay, disaggregated by sex, within a job category. This right does not, however, apply until 2028. Employers will also not be obliged to disclose that information to the individual if the level of remuneration of another specific employee could be determined from it. 

Restrictions on discussing pay 

Employers may require employees to keep the average level of remuneration confidential, except in cases when they are exercising their right to equal pay. In addition, employers cannot restrict employees from disclosing their own pay information. Contractual provisions under which an employee undertakes to maintain confidentiality regarding their remuneration or is otherwise prevented from disclosing their remuneration to another person are invalid. 

Joint pay assessments 

Where a gender pay gap of 5% or more is identified and not justified or remedied within six months from the submission of the pay report to the Ministry of Labour, a joint pay assessment is required. 

Same-sex equal pay claims 

The Equal Pay Act confirms that employees of the same sex also have the right to equal pay. The right applies when they perform the same work or work of equal value. This provision represents one of the Act’s most significant elements of gold-plating.  

Employers who approach compliance solely through the lens of male-female pay gaps may face claims they have not anticipated. Consider a tech company where 90% of engineers are male, but individual salaries vary widely. Negotiation, market timing, commission structures or simply unfair practices may cause those differences. Under traditional equal pay frameworks, the absence of opposite-sex comparators would leave most pay disparities unchallengeable – only those differences between gender could be challenged.  

Slovakia’s approach changes this position entirely.  

Every employee performing work of equal value can now compare themselves to every colleague, regardless of sex, and employers must be able to justify the gap. In essence, Slovakia has legislated for not just equal pay, but fair pay.

Job evaluation criteria  

The Directive refers to ‘skills’ and ‘effort’. Slovakia’s Equal Pay Act replaces these with ‘complexity’ and ‘strenuousness’.   

It also specifically requires employers to consider soft skills, particularly social and communication skills. We expect these terms to effectively align with the Directive.  

Slovakia’s Equal Pay Act effectively places a positive obligation on employers to consider social and communication skills as part of job evaluation criteria. This represents modest gold-plating. 

Response deadlines  

The Pay Transparency Directive requires a substantiated reply when employees question inaccurate or incomplete pay information. However, it does not set a timeframe for this.  

By contrast, Slovakia’s legislation requires employers to provide those details within 30 days of the request.  

Similarly, the Pay Transparency Directive requires employers to respond to additional questions regarding pay reports within a reasonable time. Slovakia sets a 30-day deadline for this. 

Two-month window for joint pay assessments  

The Pay Transparency Directive does not set a timeframe for completing joint pay assessments. Slovakia requires employers to complete them within two months from the date the obligation arises. In practice, a joint pay assessment is a significant and complex undertaking.

First reporting window 

The Pay Transparency Directive sets a date by which first reports must be submitted but does not confirm the periods that they should cover. The European Commission likely intended reports due on 7 June 2027 (i.e. by employers with 150 or more employees) to cover a full calendar year. Slovakia’s legislation requires these initial reports to cover only 1 August 2026 to 31 December 2026. 

Penalties  

On its face, the Equal Pay Act sets fines of EUR 4,000 to EUR 8,000 for reporting failures. These fines are unlikely to satisfy the Pay Transparency Directive’s requirement for ‘effective, proportionate, and dissuasive’ penalties, particularly for larger employers.  

However, the picture is broader than those headline figures suggest. As the correlation table accompanying draft versions of Slovakia’s law explains, the effect of the Equal Pay Act is to amend Slovakia’s Labour Inspection Act to give the Labour Inspectorate broader sanctioning powers. The Equal Pay Act therefore gives the Labour Inspectorate the power to issue fines up to EUR 100,000 for breaches of other employer obligations arising from the Equal Pay Act. Nevertheless, the Act contains no specific provision on repeat offences. This omission may represent an area of possible under–implementation. 

More recently, on 30 June 2026, the Ministry of Labour and Social Affairs issued explanatory guidelines on Slovakia’s Equal Pay Act. They do not create new legal obligations and are not legally binding. 

Although non-binding, the guidelines offer practical insights on pay structures, objective justifications for pay differences and other aspects of compliance.  

In particular, the guidelines give employers a clearer basis for reviewing their existing job classification and pay-setting processes. The recommended methodology included in the guidelines is based on an analytical point method, using a 1,000-point maximum as a reference for comparing the value of different jobs. 

This may, however, present challenges for multinational employers. Many already have their own job evaluation methodologies in place, which often differ from the approach recommended by the guidelines. In particular, such methodologies may not adequately reflect ‘working conditions’ as a statutory job evaluation criterion under Slovak law. Such employers may therefore need to adjust their existing methodologies to ensure compliance with the Slovak requirements. The guidelines could act as a useful reference point in this regard.  

A further practical challenge arises from the tendency of multinational employers to develop uniform documentation and methodologies across jurisdictions. As the guidelines reflect the specific requirements and practical conditions applicable in Slovakia, a purely global approach may not sufficiently address local legal requirements. This could ultimately result in non-compliance with the statutory equal pay obligations. Again, employers with operations in Slovakia may find the guidelines to be a useful tool when it comes to implementing the new rules.  

For employers with operations in Slovakia, immediate priorities include:  

• Reviewing and establishing compliant pay structures. The deadline for employers to establish compliant pay structures was 31 July 2026. Employers who have not yet done so should therefore treat this as an immediate priority and take the necessary steps to ensure compliance as soon as possible. Employers should not underestimate the groundwork required to do this effectively, especially for SMEs who have not undertaken a job evaluation process previously.

• Reviewing and updating recruitment procedures and implementing them in practice. Effective since 7 June 2026, employers must place greater emphasis on providing applicants with information on remuneration at a sufficiently early stage of the recruitment process to enable them to negotiate their remuneration effectively and transparently. Employers should therefore ensure that their recruitment rules and practices are aligned with these requirements without delay. 

• Auditing pay gaps broadly, including between employees of the same sex, to identify potential issues and ensure compliance with Slovakia’s expanded equal pay protections. 

• Mapping divergences across jurisdictions, as a trend is emerging where different Member States elect different key dates for similar obligations. For example, Slovakia requires reports to be filed on 15 April, whereas the Czech Republic’s and Latvia’s proposals are that they be required by 30 April and 1 June, respectively.