One of the most significant social policy instruments adopted by the EU in the last years is the EU Pay Transparency Directive (Directive (Eu) 2023/970 of the European Parliament and of the Council of 10 May 2023 to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms. Member States have until 7 June 2026 to transpose this Directive into their national legal system. The Directive contains rather strictly defined rules (read our summary here), leaving little room for national interpretation or a margin of appreciation. Nonetheless, it will be interesting to see how the EU Member States are implementing the rules. Below, we give an overview of the transposition status in July 2025.
The only official transposition overview can be found on the EUR-Lex database, which only takes into account adopted legislative transposition measures. For now, it only features a Regional Decree of the French-speaking Community of Belgium (which only has a specific competence for certain public sector workers). This means that, for now, a formal transposition is still pending in all 27 member states, but some are proceeding faster than others. The overview below is based on limited high-level research of the status in July 2025.
- Belgium: The national social partners are renegotiating the existing CBA no. 25 on equal pay for men and women. They are expected to finalise their negotiations by October. However, also the legislator will presumably need to intervene to adapt or replace the current Pay Gap Act of 2012. Next, the already adopted Regional Decree of the French-speaking Community mostly copy-pastes the Directive. However, it specifies that the pay range should be advertised in the job advertisement itself and that the employer can be sanctioned with a fine of up to 3,900 EUR.
- Finland: In May 2025,A working group under Finland's Ministry of Social Affairs and Health published a comprehensive draft to transpose the Directive by amending the national Equality Act (609/1986). The government is expected to formalise this draft in the autumn of 2025. The draft seems to stick fairly close to the obligations of the Directive, of course taking into consideration the strong position of the social partners in Finland. Non-compliance can be sanctioned with fines of 5,000 to 80,000 EUR.
- Ireland: Ireland published the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 in January 2025 with draft pay transparency provisions (salary ranges in job ads, pay history ban), amending the Employment Equality Act of 1998. This draft only covers mandatory salary ranges in job advertisements (going beyond the Directive) and the ban on asking employees about their pay history. The other obligations of the Directive are not covered by this proposal.
- Lithuania: The Ministry of Social Security & Labour officially presented draft legislation transposing the EU Pay Transparency Directive to its Tripartite Council in late May 2025. The Act seems to go slightly beyond the obligations of the Directive as it requires, e.g. that the salary range is to be included in the job advertisement. Penalties range from 400 to 6,000 EUR.
- Netherlands: The Dutch government released a draft bill in March 2025 to transpose the Directive via amendments to key national laws: the Equal Treatment Act, Works Councils Act, and Labour Allocation by Intermediaries Act. The public consultation phase closed on 7 May 2025. The Draft features a very minimal and literal transposition, covering only what is strictly necessary to transpose the Directive. The draft is expected to be submitted to the House of Representatives in Q3 of 2025.
- Malta: A Legal Notice 112 of 2025 was published on 27 June 2025 and will enter into force on 27 August 2025. This Notice only includes two aspects: the obligation to disclose the salary range before employment starts and the obligation to give information regarding the pay range to workers. Other aspects require further legislative interventions.
- Poland: In December 2024, a draft amendment to Poland's Labour Code to transpose aspects of the Pay Transparency Directive was submitted but consequently rejected by the Sejm (the parliament) in February 2025. However, a reworked draft was adopted on 4 June 2025 and sent to the Senate. It is expected that both houses will approve the law and that it will be published by the end of the year, so it will enter into force by June 2026. Also, the Polish draft includes an obligation to include the pay range in job adverts. However, the draft does not include the obligations regarding gender pay gap reporting, which will need to be addressed by later legislation (which presumably will be too late to meet the transposition deadline).
- Sweden: Sweden released a draft proposal in
May 2024, being the first member state to do so. This draft
proposal has passed the consultation phase with stakeholders but
has not yet been submitted to parliament for adoption. The proposal
goes beyond the Directive in several aspects:
- It proposes that this information be disclosed in the job advertisement (earlier and more transparently).
- It includes stronger enforcement mechanisms and proposed guidance for recruiters regarding the prohibition of asking candidates about their pay history.
- It proposes a fifth criterion to the definition of "work of equal value": "complexity of tasks".
- It has a lower reporting threshold: as from 10 workers (while 100 is the Directive's threshold).
- Trade unions have a right to request pay info for comparison without the worker's consent.
In the other Member States, there are not yet publicly available drafts, although Germany is expected to publish a draft in late 2025. As usual, it is expected that a significant number of countries will not meet the transposition deadline, including some of the member states that are mentioned above, as they only have provided drafts for a partial transposition.
From the overview above, we can learn that most countries will stick fairly close to the obligations of the Directive, but a large number of Member States will make it mandatory to publish the salary range in job advertisements, while this is obligatory under the Directive. Especially Sweden seems to go beyond the Directive, lowering the reporting threshold to employers with 10 workers or more.
Please take into consideration that the above information is not final and does not reflect a detailed research of the draft legislation. This is merely meant to give a first indication of where the EU member states are heading.
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