The EU Pay Transparency Directive: Progress Towards June 2026

The EU Pay Transparency Directive is no longer on the distant horizon; 7th June 2026, the date by which member countries must transpose the Directive into law, is rapidly approaching. The EUPTD, which entered force on 7th June 2023, requires:

• That employers publish pay levels/ranges prior to employment
• Transparency around the setting of pay and gender-neutral job evaluation criteria
• That employees have access to information around how their pay compares to others doing the same or similar work
• Reporting of pay gaps between male and female workers – both on a whole organisational level, and between 'categories' of workers
• Taking action to amend pay gaps considered to be above an acceptable level, involvement of unions and similar

As such, the EUPTD is a structural shift in how organisations design, manage, and communicate pay and benefits across the European union and potentially beyond.

Reward Heads has published regular updates on where different member states are at on their journey to pay transparency, so we’ve published a quick round-up of where different states are currently and what you should be thinking about as the deadline for implementation creeps ever closer.

Member State Highlights (as of October 2025)

• Belgium: Partial regional implementation (public sector first). Private-sector expansion expected in 2026.
• Finland: Draft law published (May 2025); aligns closely with Directive principles.
• France: Consultation underway; “Equality Index” reform expected 2027.
• Germany: Commission drafting a new framework; existing law falls short.
• Ireland: Expanded gender pay reporting to 50+ employees from 1st June 2025
• Malta: Recruitment transparency rules in force (August 2025); reporting rules to follow.
• Netherlands: Draft law ready but implementation delayed to Jan 2027.
• Poland: Recruitment pay disclosure effective December 2025; broader pay reporting still in draft.

Many others, including Spain, Greece, Slovakia, are still drafting their proposals at time of writing.

Priorities as we await final details

If your organisation will be affected by the Directive, now is the time to begin preparing in advance if you haven’t already. So what should you be thinking about?

• Review your pay framework and HR systems: do you have a robust framework that supports disclosure and explanation of pay gaps? Can your systems produce the required information, particularly for Gender Pay Gap (GPG) reporting?
• Review and, if needed, refresh your levelling framework: Have you written down objective, gender-neutral criteria to define “equal work”? Have you ensured that your current framework is robust and supports compliance with the legislation?
• Plan for pay transparency communications: Are your leaders equipped to discuss pay openly? Do they understand the Directive’s requirements? Have they been briefed on what pay transparency means and will look like at your organisation?
• Pilot reporting now: Have you tried testing the GPG reporting process early and made sure you can definitely produce the required statistics using your current systems?
• Monitor national “gold-plating”: Have you researched in-depth the rules that your member state will implement? And, if you operate in more than one member state, have you researched what the rules will be in each of them? Legislation will vary from member state to member state and some states will go beyond the EU minimum, so you need to be sure your current systems and processes can accommodate all that is required under your local legislation.

The key takeaway from this is that the Directive’s impact goes far beyond gender pay equity; it will redefine pay and reward governance across the EU, and potentially beyond. Reward teams that act early will shape the conversation, not just react to it.

At Reward Heads, we have many years of experience across the team in the area of pay transparency and would love to support you in your journey, or if there are other countries where your organisation operates and you'd like to understand the impacts of the EUPTD there, please reach out on rewardsolutions@rewardheads.co.uk.

For those not impacted by the EUPTD, we also run online coaching modules on a variety of Reward topics and have an entire 3-module bundle on Pay covering:

• Managing and Maximising Base Pay
• National Minimum Wage
• Benchmarking Overview

You can find them here: Coaching Modules on Pay

We also recently released a module focusing on Mastering Pay Transparency (not focusing on the EUPTD) and the journey to achieving it, which you can learn more about here: Mastering Pay Transparency