Pay Transparency Directive: country status
Built for employers with 150+ workers (first report due 7 June 2027 under the Directive). 100–149 workers: first report due 7 June 2031. Under 100: no obligation under the Directive.
Status of national laws implementing Directive (EU) 2023/970. Each row summarises the linked source in one line; it is not a legal opinion. Check the source and your national law before relying on it.
Article 9 reporting under the Directive (national law may differ)
- 250+ workers: first report by 7 June 2027, then every year.
- 150–249 workers: first report by 7 June 2027, then every three years.
- 100–149 workers: first report by 7 June 2031, then every three years.
- Under 100 workers: no obligation under the Directive (Member States may add one).
| Country | Status | National first report (if different) | Note | Source | Last checked |
|---|---|---|---|---|---|
| Poland PL | Partly transposed | — | Pay transparency at recruitment has applied since 24 Dec 2025 (Labour Code). The full implementing bill (UC127, version 2.0 of 25 May 2026) is on the government work list with Council of Ministers adoption planned for Q4 2026. | gov.pl (KPRM, wykaz prac legislacyjnych) source dated 2026-05-25 |
|
| Slovakia SK | Transposed | — | Listed as transposed, effective 7 June 2026. | Morgan Lewis source dated 2026-06-08 |
|
| Italy IT | Transposed | 2027-06-07 (150+); 2031-06-07 (100–149) | Legislative Decree No. 96/2026 in force since 7 June 2026; reporting for 100+ workers on the Directive's timetable. | Pinsent Masons (Out-Law) source dated 2026-07-09 |
|
| Netherlands NL | Draft bill | — | Draft bill published; deadline missed. Entry into force expected 1 January 2027. | Morgan Lewis source dated 2026-06-08 |
|
| Germany DE | No bill published | — | No government bill yet; deadline missed. In July 2026 the federal government told the Bundestag a low-bureaucracy bill was being prepared. The existing Pay Transparency Act (EntgTranspG) still applies. | Deutscher Bundestag (hib 587/2026) source dated 2026-07-16 |
|
| Ireland IE | No bill published | — | Deadline missed; the government plans phased implementation. Legislation still being drafted, no dates confirmed. | Pinsent Masons (Out-Law) source dated 2026-07-09 |
|
| France FR | Draft bill | — | Transposition bill presented to the Council of Ministers on 10 September 2026; not yet adopted by Parliament. | Élysée, compte rendu du Conseil des ministres source dated 2026-09-10 |
|
| Spain ES | No bill published | — | No implementing draft published as of the source date. Existing pay register rules (since 2020) do not cover all new duties. | Pinsent Masons (Out-Law) source dated 2026-07-09 |
|
| Malta MT | Transposed | — | Equal Pay (Transparency and Reporting) Regulations 2026 published 5 June 2026. | Pinsent Masons (Out-Law) source dated 2026-07-09 |
|
| Lithuania LT | Transposed | — | Labour Code amendments adopted 21 May 2026, in effect 7 June 2026; some duties apply from 2027. | Pinsent Masons (Out-Law) source dated 2026-07-09 |
|
| Czechia CZ | Draft bill | — | Delayed; implementation date given as 1 January 2027. | Morgan Lewis source dated 2026-06-08 |
Other Member States: not yet tracked.
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