As of mid-April 2026, no Member State has fully completed nationwide transposition of Directive (EU) 2023/970 on pay transparency. The transposition deadline of 7 June 2026 is imminent, yet the majority of Member States either have published only a partial text, a draft circulated for consultation, or nothing at all. The summary below reflects the situation as at April 2026 and will require updating as national legislative procedures accelerate in the weeks ahead.

The clearest gold-plating signals appear in Lithuania, France, Ireland and Denmark. Partial gold-plating is also visible in Poland and the Netherlands. Sweden presents a unique situation: after publishing draft legislation in early 2026, the government announced on 26 March 2026 that it opposes the Directive and seeks renegotiation at EU level — making it the only Member State to have publicly withdrawn from the transposition process. KEY FINDINGS  ·  APRIL 2026
Partial transposition already in force	4 member states (BE, CZ, MT, PL)
Draft legislation published	9 member states
No public draft available	13 member states
Draft publicly withdrawn	Sweden (SE)
Gold-plating confirmed or signalled	7 member states (DK, FR, IE, IT, LT, NL, PL)
Transposition deadline	7 June 2026 — no Member State has fully transposed

 

Transposition overview — all 27 Member States

The table below sets out the current transposition status and any gold-plating signals for each Member State. Hover over national entries in the interactive dashboard for further detail.

Member State	Transposition status	Gold-plating	Key points
Austria	No public draft	N/A	No preparatory work publicly reported.
Belgium	Partial in force	No GP expected	FWB & Flemish public-sector measures. No private-sector federal draft yet — expected soon.
Bulgaria	No public draft	N/A	Preparatory work referenced but no public text.
Croatia	No public draft	N/A	Advisory planning; spring 2026 activity expected.
Cyprus	Draft published	No gold-plating	Consultation draft. Clean transposition; strong enforcement; focus on post-leave pay progression.
Czech Republic	Partial in force	No GP expected	Pay secrecy clauses banned from 1 June 2025; broader draft pending.
Denmark	Draft published	GOLD-PLATING	Consultation draft (26 Feb 2026). Reporting extends to 50–99 employees via statistics model. Implementation: 1 Jan 2027.
Estonia	No public draft	N/A	Preparation work said to be under way.
Finland	Draft published	Limited GP	Government states no gold-plating intent, but layered obligations under existing equality-plan duties (30+ employees).
France	Draft published	GOLD-PLATING	Draft circulated 6 March 2026. Threshold lowered to 50 employees (vs 100 in Directive). Penalty: up to 1% payroll.
Germany	No public draft	No GP signalled	Commission report published Nov 2025. “Bureaucracy-light” approach; no draft bill; threshold expected at 100 employees.
Greece	No public draft	N/A	Specialist committee preparing framework.
Hungary	No public draft	N/A	No public draft reported.
Ireland	Draft published	GOLD-PLATING	General Scheme 2024. Pay ranges required in job ads (not just before interview). Website publication obligation beyond Directive.
Italy	Draft published	Mixed (see note)	First draft legislative decree. GP: pay structure in job ads; proactive intranet publication. Narrower: apprenticeships, domestic work, on-call excluded.
Latvia	No public draft	N/A	No public draft published.
Lithuania	Draft published	GOLD-PLATING	Clearest GP jurisdiction. Remuneration policies mandatory for ALL employers. Monthly pay reporting via social security. No size exemption.
Luxembourg	No public draft	N/A	Draft bill signalled as forthcoming.
Malta	Partial in force	Narrower scope	In force since 27 Aug 2025. Scope narrower than Directive: disclosure delay allowed; right to info limited to “same work” only.
Netherlands	Draft published	Limited GP	Draft bill (March 2025). Mostly literal transposition. GP: works council consent rights; temp agency workers in scope. Delay to 1 Jan 2027.
Poland	Partial in force	Limited GP	Recruitment rules in force 24 Dec 2025. Broader draft: GP features include 30-day response deadline, fixed 31 March notice date.
Portugal	No public draft	N/A	Working group and capacity-building under way.
Romania	No public draft	N/A	Draft being prepared; expected but not yet published.
Slovakia	Draft published	No gold-plating	Most advanced. Approved by government Dec 2025; submitted to parliament Jan 2026. Clean transposition. Minor: earlier reporting deadline.
Slovenia	No public draft	N/A	Working group preparing legislation.
Spain	No public draft	N/A	Existing pay-register & pay-audit obligations under national law, but no transposition draft.
Sweden	Draft withdrawn	Was GP	Draft referral 15 Jan 2026, then reversed on 26 Mar 2026. Government opposes Directive; seeks renegotiation. No bill to Riksdag.

 

Gold-plating: a closer look

Gold-plating occurs where a Member State imposes obligations on employers that go beyond the minimum standards set by the Directive. The main types of gold-plating identified so far are set out below.

1.  Scope of application — employer thresholds

The Directive sets a general reporting threshold of 100 employees. France lowers this to 50 employees, which significantly expands the number of employers subject to gender pay gap reporting obligations. Denmark achieves a similar effect by routing employers in the 50–99 employee band through its existing statistics-based model.

2.  Pre-employment transparency obligations

Ireland requires pay ranges to be published in job advertisements rather than merely disclosed before the interview, as the Directive would require. Ireland also maintains a website publication obligation that goes beyond the Directive’s framework. Similarly, Italy’s first draft legislative decree requires detailed pay-structure information directly in job advertisements.

3.  Universal employer obligations — Lithuania

Lithuania presents the most far-reaching gold-plating. Its draft would impose mandatory remuneration policies on all employers regardless of headcount, introduce monthly pay and working-time reporting through state social-security channels, and remove all size-based exemptions for formal gender-neutral pay structures. This materially exceeds every benchmark in the Directive.

4.  Procedural requirements — Poland

Poland illustrates “near-literal transposition plus tougher procedural deadlines”: its broader draft includes a 30-day deadline for right-to-information responses (shorter than the Directive), a fixed 31 March annual notice date, and very tight explanation timelines when trade unions or equality bodies request information.

5.  Works-council rights — Netherlands

The Netherlands grants works councils consent rights in areas where the Directive would only require lighter consultation, and extends the personal scope to include temporary agency workers. Both additions exceed the Directive’s minimum requirements.

Special case: Sweden

Sweden stands apart from all other Member States. After the government published a legislative referral on 15 January 2026 proposing amendments to the Discrimination Act with a proposed entry into force of 1 July 2026, it reversed course on 26 March 2026. The Swedish government announced that it considers the Directive too administratively burdensome, wishes to postpone the implementation deadline, seeks renegotiation at EU level, and does not currently intend to submit a transposition bill to the Riksdag. This is a remarkable turn: the early drafts that had been released in 2025 were themselves examples of gold-plating (the existing national obligation to conduct pay surveys for all employers would have been retained alongside the new Directive-based reporting layer).

Outlook

With the 7 June 2026 deadline now weeks away, the pace of transposition activity is likely to accelerate sharply. Several Member States — including Germany, Spain and Romania — are expected to publish draft texts in the coming weeks. Belgium is expected to circulate a federal private-sector draft shortly. Based on current signals:

• A number of Member States will transpose on or close to the deadline but without full legislative enactment, likely relying on interim measures or decrees.
• Gold-plating will be a feature in at least five to seven Member States; the practice is most concentrated in pre-employment transparency and employer headcount thresholds.
• Several Member States (at least ten) will face infringement proceedings for failure to transpose on time, unless their legislative processes accelerate significantly.
• The interaction between the Pay Transparency Directive and existing national pay-audit and gender pay gap reporting frameworks (Finland, Ireland, the Netherlands, Sweden) will require careful legal analysis for multinational employers.

 

This update will be revised as national drafts are published. For country-specific advice, please contact the relevant L&E Global member firm.