The EU Pay Transparency Directive: an employer guide
The EU Pay Transparency Directive makes employers open about pay and accountable for gender pay gaps. Member states had until 7 June 2026 to write it into national law, and they are moving at very different speeds.
Find your country
Of the 27 EU member states, 4 have the rules in force, 1 partly, 13 are still drafting, and 9 have not started. Pick a country for the full guide, or open the transposition tracker.
27 member states
In forceItaly
In forceLithuania
In forceMalta
In forceSlovakia
Partly in forcePoland
Bill in progressBulgaria
Bill in progressCyprus
Bill in progressCzechia
Bill in progressDenmark
Bill in progressEstonia
Bill in progressFinland
Bill in progressFrance
Bill in progressGreece
Bill in progressIreland
Bill in progressLatvia
Bill in progressNetherlands
Bill in progressRomania
Bill in progressSlovenia
Not yet transposedAustria
Not yet transposedBelgium
Not yet transposedCroatia
Not yet transposedGermany
Not yet transposedHungary
Not yet transposedLuxembourg
Not yet transposedPortugal
Not yet transposedSpain
Not yet transposedSweden
Of the 27 EU member states, only about four had a full national transposing law actually in force by the 7 June 2026 deadline: Italy, Slovakia, Lithuania and Malta. A few others had partial measures in force, such as Poland’s recruitment rules. The large majority, including Germany, France, Spain and the Netherlands, missed the deadline.
What does the EU Pay Transparency Directive do?
It sets a single EU-wide floor for openness about pay. Employers must share pay information with job applicants and employees, report their gender pay gap, and fix unexplained gaps. The goal is to make equal pay for equal work enforceable in practice, not just a principle on paper.
Who has to comply, and when?
All employers must meet the transparency duties for applicants and employees once their country has transposed the Directive. Gender pay-gap reporting is phased by size. Employers with 250 or more workers report first, by 7 June 2027, and then every year. Employers with 150 to 249 workers also report first by 7 June 2027, then every three years. Employers with 100 to 149 workers report first by 7 June 2031, then every three years. Under 100 employees, there is no EU-wide reporting duty, though member states can go further.
What must employers tell job applicants?
Before the interview, candidates must be told the starting pay or pay range for the role, usually in the job advert or before the first interview. Employers cannot ask candidates about their pay history. Job titles and selection criteria must be gender-neutral, and the recruitment process must be run without discrimination.
How does gender pay-gap reporting work?
Employers above the size thresholds must report the gap between the average pay of women and men, including a breakdown by category of worker doing the same work or work of equal value. Employees gain a right to ask for information on their own pay level and the average pay levels for their category, broken down by sex. Pay-secrecy clauses that stop staff discussing pay are banned.
What is a joint pay assessment?
If reporting shows a gender pay gap of at least 5 percent in any category of workers that the employer cannot justify on objective, gender-neutral criteria, and the employer has not closed it within six months, the employer must carry out a joint pay assessment with employee representatives and put the gap right.
How does this work if you hire through an EOR?
An Employer of Record is the legal employer of your team in-country, so the pay-transparency duties for those employees sit with the EOR. Teamed handles the statutory pieces, from pay ranges in compliant job offers to reporting where it applies, while you stay the day-to-day manager. That keeps you compliant in each market without setting up a local entity.
What the Directive requires
| Pay shown before interview | Tell candidates the salary or range before the first interview, in the advert or before it. |
|---|---|
| No salary-history questions | You cannot ask candidates what they currently earn or earned in the past. |
| Right to pay information | Staff can ask for their own pay and the average pay of colleagues doing equal work, broken down by sex. |
| Gender pay-gap reporting | Employers above the size thresholds report their gender pay gap on a set schedule. |
| Joint pay assessment | An unexplained gap of 5 percent or more triggers a joint review with worker representatives. |
| Burden of proof shifts | If you have not met your transparency duties, you must prove there was no pay discrimination. |
| No pay-secrecy clauses | You cannot stop employees discussing or disclosing their own pay. |
| Effective penalties | Each country sets penalties that must be effective, proportionate and dissuasive. |
Key figures
| Detail | Value |
|---|---|
| Directive reference | Directive (EU) 2023/970 (source) |
| National transposition deadline | 7 June 2026 (source) |
| First gender pay-gap report (250+ employees) | Due 7 June 2027, then annually (source) |
| Reporting for 150 to 249 employees | First report 7 June 2027, then every 3 years (source) |
| Reporting for 100 to 149 employees | First report 7 June 2031, then every 3 years (source) |
| Joint pay assessment trigger | Unexplained gap of 5 percent or more (source) |
| Salary-history questions | Banned (source) |
| Burden of proof | Shifts to the employer (source) |
Frequently asked questions
Does the Directive apply if my country has not transposed it yet?
The duties take legal effect in a country once that country has written the Directive into national law. Where a member state missed the 7 June 2026 deadline, some parts of the Directive can still have effect against the state and public bodies, but the practical employer duties usually land when the national law is in force. The tracker shows where each country stands.
Do small companies have to report their gender pay gap?
Reporting is phased by size. Employers under 100 employees have no EU-wide reporting duty, although individual member states can set lower thresholds. The transparency duties for job applicants and employees apply to employers of all sizes.
Can we still ask candidates what they earn now?
No. The Directive bans asking job applicants about their current or past pay. Instead, you must tell candidates the pay or pay range for the role before the interview.
Who is responsible if we hire through an Employer of Record?
The EOR is the legal employer, so the statutory pay-transparency duties for those employees sit with the EOR. Teamed handles compliant pay ranges, the right-to-information requests, and reporting where it applies, in each market.
Pay transparency is landing across the EU at very different speeds. When Teamed is your legal employer, these duties sit with us in every market: compliant pay ranges, the salary-history rule, employee pay-information requests, and reporting where it applies. We track the law country by country so your hiring stays compliant.
