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.

Below, we highlight developments that took place (or did not take place, as the case may be) between July and August 2026. For further details regarding these developments, please see the above transposition tracker. 

Changes in transposition status

• Estonia: Changed from ‘draft’ to ‘partially transposed’. The amendment law that partially transposes the Pay Transparency Directive was approved by the President of Estonia on 29 June 2026 and published in the State Gazette on 3 July 2026. The amendments partially transposing the Directive entered into force on 13 July 2026.
• Greece: Changed from ‘draft’ to ‘transposed’. Law no. 5316, which fully transposes the Pay Transparency Directive, was published in the Government Gazette on 6 July 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 ends on 25 August 2026.

Other noteworthy developments

• Bulgaria (draft): Bulgaria had generally been expected to transpose the Directive by the end of July 2026. This did not materialise.
• Czech Republic (draft): Following a comment review process which ended on 14 July 2026, an updated draft law was published on 16 July 2026. It includes several changes to the Czech Republic’s first draft law transposing the Directive.
• Finland (draft): On 9 July 2026, the Finnish Government published its updated proposal to transpose the Pay Transparency Directive. This follows the initial draft proposal published back on 16 May 2025. The updated draft amending legislation is set out at the end of the Government proposal document. The proposal (and draft amending legislation) remains subject to parliamentary consideration, and may therefore be amended or clarified during this process.
• France (draft): The most recent indication from the Ministry of Labour, based on comments made in an interview on 29 June, is that the transposition Bill was submitted to the Council of State in June 2026, will be discussed before the Parliament during the second half of 2026 and will be voted on early in 2027. It was also anticipated that it would be submitted to the Council of Ministers in July 2026, but this did not happen.
• Germany (initial steps): On 16 July 2026, the German Federal Parliament (the Bundestag) press service published a short notice regarding Germany’s transposition of the Directive.
• Ireland (draft): Ireland’s Pay Transparency Bill was not given priority drafting status under the Irish government’s Summer legislative programme.
• Lithuania (transposed): The Minister of Social Security and Labour issued implementing regulations on 17 July 2026 which took effect on 31 July 2026. These contain additional details around collection, calculation, submission, and publication of employee pay data to Sodra, and the procedure for conducting joint pay assessments.
• Netherlands (draft): On 9 July 2026, a draft ministerial regulation on gender pay gap reporting and a draft reporting form, template, and data specification were published. These additional documents are open for public consultation until 11 September 2026. This is separate to the consultation on the draft Order in Council (‘Algemene maatregel van bestuur’, ‘AMvB’), which ended on 31 July 2026. The AMvB is a set of detailed regulations that further elaborate on the provisions set out in the bill to transpose the Pay Transparency Directive.