Directive (EU) 2023/970 · Transposition tracker
Only four member states transposed the EU Pay Transparency Directive on time. The other 23 are somewhere between a confirmed 2027 date and total silence - and from 8 June 2026 the laggards are formally in breach. This page tracks all 27 member states: what is in force, what is delayed, and what your HR team owes whom, obligation by obligation.
Last reviewed: June 12, 2026 · re-checked against the sources listed at the bottom of this page
Status of national transposition of Directive (EU) 2023/970 as of the review date above. “What applies” columns show the national rule where one is in force, the directive baseline where the national law follows it, and “-” where nothing is in force yet. Country notes are shown in English in every language. This is a tracker, not legal advice.
| Member state | Status | Pay range to applicants (Art. 5) | Employee inquiry right (Art. 7) | Gap reporting (Art. 9) | Effective / target | Notes |
|---|---|---|---|---|---|---|
| Italy | Live | In the job posting (mandated) | Live | 150+ · first report Jun 2027 | Live since 7 Jun 2026 | Gold-plates Art. 5: the pay range must appear in the vacancy notice itself, not just before interview. |
| Slovakia | Live | Before interview (posting optional) | Live | 150+ · first report Jun 2027 | Live since 7 Jun 2026 | Transposed on time; follows the directive baseline. |
| Lithuania | Live | Before interview (posting optional) | Live | 150+ · first report Jun 2027 | Live since 7 Jun 2026 | Transposed on time; follows the directive baseline. |
| Malta | Live |
Four articles do most of the work in this directive. Here is each one in plain HR language - and what to prepare even if your member state is late.
Applicants get the initial pay or pay range for the role - in the posting or at the latest before the interview. You may no longer ask candidates about their pay history. Italy already mandates the range in the posting itself; Ireland's draft does too. If you recruit across borders, build the posting-range habit now.
Generate a defensible range, with receiptsEmployees must be able to see the criteria used to set pay, pay levels and pay progression - and those criteria must be objective and gender-neutral. In practice: a written pay policy that survives being read aloud. Member states can exempt sub-50-employee firms from the progression part only.
Any employee can request - in writing - their individual pay level and the average pay level, broken down by sex, for their category of work. You must answer within two months, with the receipts. You cannot contractually forbid workers from disclosing their own pay.
Draft an Art. 7 responseEmployers with 150+ employees report their gender pay gap from June 2027 (100+ from 2031). If a gap of more than 5% in any category cannot be justified by objective criteria, a joint pay assessment with worker representatives is triggered. France's draft lowers the threshold to 50+ employees with penalties up to 1% of payroll.
Most tooling chases the directive downward: salary bands, gender-gap reporting, grids for the workforce. But the same law turns the spotlight upward: pay criteria must be objective, ratios get computed, and “why is the CEO package structured like this?” becomes a question with a paper trail. That upward half needs disclosed, citable market data, not panel averages.
For HR teams
The reference doc your CSE, COMEX or comp committee will ask for: compensation philosophy and structure, a cited market benchmark, employee share ownership and benefits framework, and a directive-readiness section. Comp4AI interviews you, drafts each section, and exports a branded PDF.
For comp committees & advisors
Where does your executive pay actually stand, and can you defend it? Named listed comparables, percentile positioning, pay-mix and equity practice: the answers an AGM or a journalist will now expect, with the receipts attached.
Justifying pay decisions with an anonymous panel average is answering a transparency question with a black box. Comp4AI benchmarks come from what listed companies legally disclosed: 10k executive pay records across 12k companies, each one clickable through to the filing page. When the document is challenged, it defends itself.
Status data on this page is compiled from the directive text and the trackers and law-firm analyses below, re-checked on the review date. Found something out of date? We update within a business day.
Last reviewed: June 12, 2026 · re-checked against the sources listed at the bottom of this page
| Before interview (posting optional) |
| Live |
| 150+ · first report Jun 2027 |
| Live since 7 Jun 2026 |
| Transposed on time; follows the directive baseline. |
| Poland | Partial | Recruitment-stage rules live | - | - | Partial since 24 Dec 2025 | Recruitment-stage pay transparency rules in force since 24 Dec 2025; full transposition still pending. |
| Belgium | Partial | - | - | - | Partial (public sector, FWB) | Fédération Wallonie-Bruxelles decree in force since 1 Jan 2025 (French Community public sector only); federal private-sector draft pending. |
| Netherlands | Delayed - dated | - | - | - | 1 Jan 2027 (confirmed) | Government has officially confirmed a delayed entry into force of 1 Jan 2027. |
| Sweden | Delayed - dated | - | - | - | Paused - seeking renegotiation | On 26 Mar 2026 the government paused transposition, calling the directive too burdensome and seeking renegotiation at EU level. No bill before the Riksdag. |
| Czech Republic | Delayed - dated | - | - | - | 1 Jan 2027 (target) | Confirmed delayed implementation targeting 1 Jan 2027. |
| Denmark | Delayed - dated | - | - | - | 1 Jan 2027 (draft bill) | Draft bill published; entry into force planned for 1 Jan 2027. |
| France | Draft | Per draft: directive baseline | - | 50+ employees (draft gold-plate) | 1 Jan 2027 (target) | Draft law published 6 Mar 2026. Gold-plates with a 50-employee reporting threshold and penalties up to 1% of payroll. |
| Ireland | Draft | In the job posting (per draft) | - | - | Missed deadline - draft in progress | Draft mandates the pay range in the job posting itself (like Italy), but Ireland missed the 7 Jun 2026 deadline. |
| Finland | Draft | - | - | - | Draft expected mid-Jun 2026 | Ministry of Social Affairs and Health rescheduled in May 2026; draft expected mid-June 2026. |
| Germany | No draft notified | - | - | - | - | No draft published. Existing Entgelttransparenzgesetz (2017) remains the national baseline meanwhile. |
| Spain | No draft notified | - | - | - | - | Public consultation on a Royal Decree closed 8 May 2026; no draft text published yet. |
| Austria | No draft notified | - | - | - | - | No published draft as of 30 Apr 2026. |
| Portugal | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Greece | No draft notified | - | - | - | - | Pre-draft stage; a specialist committee was due to report by 28 Feb 2026. No draft or consultation paper published. |
| Hungary | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Luxembourg | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Croatia | No draft notified | - | - | - | - | No public draft; no specific national pay transparency regime in place. |
| Bulgaria | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Romania | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Slovenia | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Estonia | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Latvia | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
| Cyprus | No draft notified | - | - | - | - | No transposition notified to the Commission as of 12 Jun 2026. |
The directive does not apply to the UK and there is no equivalent pay-range mandate. But the market moved anyway: roughly 56% of UK job postings now disclose pay voluntarily, and gender pay gap reporting has been mandatory for 250+ employee organisations since 2017.
Direction of travel: even where transposition is late, the directive's floor - range before interview, salary-history question ban, inquiry rights, gap reporting - is what national laws will converge on. Building to the baseline now is cheaper than retrofitting in 2027.