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.

Change in transposition status (October/November 2026)

• Croatia: Status changed from ‘Initial Steps’ to ‘Draft’ after Croatia published its draft transposition of the Directive on 2 November 2026.

Other noteworthy developments for October/November 2026

• Czech Republic (draft law): The first reading of the draft law in the Chamber of Deputies was completed in October. If the timeline remains on track, the law could be fully adopted by the end of 2026, but this is looking increasingly ambitious.

• Finland (draft law): Parliament is now set to discuss the bill in two plenary sessions with its deliberations based on the Employment and Equality Committee’s report that was published on 22 October 2026. Against this background, it seems relatively realistic that the draft amending legislation will be adopted and enter into force on 1 January 2027. That said, since the Government proposal (and draft amending legislation) is still under parliamentary consideration, further amendments or clarifications remain possible.

• Germany (initial steps): There had been informal expectations that a draft bill (Gesetzesentwurf) could receive cabinet approval in October 2026, but this has not happened. No draft bill currently has a fixed slot on any published agenda.

• Hungary (initial steps): According to the Government’s autumn 2026 legislative programme, a bill to transpose the Directive was expected to be introduced in time for adoption in October 2026. This did not, however, happen.

• Lithuania (transposed): The State Social Insurance Fund (Lithuania’s social security authority, commonly known as ‘Sodra’) updated its guidance on 28 October 2026 regarding the formal rules, approved by the Sodra Director on 5 October 2026, for completing what is known as a transparent salary report form (or ‘SDUP form’) and correcting data contained within it.

• Romania (draft law): The draft law was rejected by the Senate on 14 October 2026. It has been forwarded to the Chamber of Deputies for further consideration. The relevant committees have until 28 October 2026 to table amendments and until 5 November 2026 to submit their report. The Chamber may adopt the draft law despite the Senate’s rejection.

*We have also added some additional details regarding Latvia’s draft legislation.