- with readers working within the Oil & Gas industries
Malta has signalled its intent to meet the 7th June 2026 deadline for transposing the Pay Transparency Directive 2023/970 (the Directive) into national law.
The landmark Directive aims to bridge gender wage gaps and enforce equal pay for equal work and work of equal value, through stringent transparency and reporting obligations. With the publication of Legal Notice 112 of 2025, Malta became one of the first EU Member States to formally implement key provisions of the Directive. Covering only part of the Directive’s scope, it illustrates a commitment to implementing the Directive timeously, while also being sensitive to business needs with a staggered implementation to facilitate proactivity. This will be yet another example of Malta’s determination to be at the forefront of the EU regulatory wave.
What Employers Need to Do
To comply with the Directive, employers of all sizes will need pay structures which are rigorously objective and gender-neutral by design, clustering roles according to the value they add. This necessitates an exercise in which all roles are evaluated according to the skills, effort, responsibility, and working conditions associated with them. This allows for the comparison of value across various roles within the organisation.
All roles within a given category would be considered “work of equal value”, regardless of the operational differences between them, and must be remunerated according to a common salary range. Each category will have its own salary band. Once a compliant pay structure has been established, gender wage gaps and individual wage outliers can be identified and either justified or addressed.
Risks of Non-Compliance
Without compliant pay structures, employers may face fines, penalties, and retroactive compensation claims from their employees. Shouldering the burden of proof, employers who are insufficiently prepared will be vulnerable to equal pay claims from employees who have access to data that clearly indicates the existence of any gender wage gaps or individual wage outliers.
Ensuring internal pay equity across the organisation entails a fundamental departure from what has often been a purely market-based analysis of salary, based on supply and demand.
Current State of Preparedness
In delivering its services, RSM Malta has observed a broad spectrum of organisational maturity when it comes to preparedness for the Pay Transparency Directive. A number of businesses have been closely tracking the Directive’s requirements from the outset, fully appreciating the risks of non-compliance and proactively allocating the resources needed to meet the deadline. Others, while less advanced in their understanding, have nonetheless recognised the urgency and are actively working towards compliance.
However, a significant proportion of businesses remain either entirely unaware of the impending legal obligations or, despite being aware, lack the structures, data, and processes required to achieve timely readiness. Others have a false sense of security. While their pay structures categorise roles into grades, they do not appreciate that the foundations of these structures are precisely what the Directive seeks to address. Traditional classifications are often rudimentary and subject to various assumptions, subjectivity, indirect discrimination, and insufficient rigour.
The Deadline
The reality is clear: every employer with workers in any EU Member State — irrespective of size, sector, or corporate structure — will be legally required to comply with the Pay Transparency Directive by 7 June 2026. With just a few months remaining, organisations must ensure they have the governance and pay structures necessary to meet this deadline.
As the deadline approaches, RSM Malta is supporting employers to move beyond awareness and into full operational readiness. Their multidisciplinary team assists organisations in assessing their current maturity, identifying pay transparency and pay-equity risks, establishing Directive-aligned pay structures and building the reporting structures required for compliance.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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