Over the last few months, developments and updates on the implementation of the EU Pay Transparency Directive have been moving at pace. In this article, we want to step-back, take a breath and look at some of the most recent and important changes, pulling information from our regularly updated Directive implementation map. We begin by highlighting two countries—Malta and Poland—that have recently enacted legislation addressing specific elements of the Directive. Then, we turn to the Netherlands, where a noteworthy draft bill is progressing through the legislative process.

For a detailed overview of implementation progress, please refer to our map at the end of this article. It highlights countries that have taken initial steps, those with draft laws in progress, and those that have partially implemented the directive.

Two countries have recently taken steps to approve legislation implementing certain parts of the Directive. In both examples, further legislation is expected to follow which will focus on the other aspects of the Directive, but these nevertheless represent important legislative milestones.

Malta: With effect from 27 August 2025, a new set of rules surrounding pay transparency came into effect in Malta, implementing certain initial aspects of the directive. The new rules provide pay transparency rights for both job applicants and existing employees. They were introduced via Legal Notice 112 of 2025 which was published on 27 June 2025.

Poland: An Act partially implementing the Directive will come into force on 24 December 2025. The scope of the Act only covers the recruitment process. Companies will have to inform candidates of their starting remuneration or wage brackets either in job advertisements or at a later stage – i.e. before the recruitment interview or before entering into the employment relationship. It should be done in advance to allow candidates to prepare for negotiations on remuneration. Employers will also have to provide candidates with information on any specific company rules on remuneration. Additionally, under the new Act, it will not be possible to ask how much candidates earned in previous jobs. Finally, job positions and job advertisements will have to be gender-neutral. The other provisions of the Directive are to be dealt with in a separate bill which is currently being worked on.

One question for many employers with operations in Europe is whether we will end up with a harmonised system of legislation across the EU, or whether it will be more patchwork in nature. We expect the position to become clearer as more countries publish draft bills. One that already has is the Netherlands, which proposed a bill to implement the Directive back in March 2025 through the amendment of three existing acts.

After the initial consultation, the bill will be submitted to the Council of State, after which the House of Representatives and the Senate will assess the bill. However, it should be noted that the caretaker status of the government in the Netherlands, as per 3 June 2025, may affect the progress of the bill in the legislative process. It will be interesting to see how this develops.

In terms of the bill itself, all employers would have to provide transparency about renumeration prior to employment, gender neutral job-titles, and would be prohibited from asking about salary history during discussions on employment terms. Employers with 50 employees must provide employees with access to the criteria used to determine wage development. Companies with 250 employees or more must report annually on pay differences between men and women, whilst companies with 100 to 249 employees must report every three years, with different deadlines for initial reporting. Employees will have the right to request information about their individual pay levels and the gender-disaggregated pay levels for categories of employees performing the same or equivalent work.

Finally, a significant number of EU countries are in the early stages of implementation, with discussions ongoing between key stakeholders on precisely how the Directive will be transposed into national law. These discussions are fast moving with a recent interesting development coming from France.

The Ministry of Labour is currently holding discussions on implementation of the directive with trade union and employer representatives at a national level, with the aim of finalising a dedicated bill by the Autumn and enacting the law in December 2025. Implementing decrees would then be examined and published by February 2026. The discussions had been scheduled to conclude in a final negotiation meeting on 9 September 2025. However, this meeting was cancelled following the resignation of the French Prime Minister. While a new Prime Minister has been appointed, it is expected that the political situation in France may delay the overall process.

With less than a year to go until the implementation deadline the legislative picture across the EU is a fast-moving one. We will continue to keep a close eye on developments as and when they occur and update our implementation map accordingly.