European Union: Pay Transparency Directive: Europe Nears the Deadline, but Most Member States are Not Ready
With the 7 June 2026 deadline for implementing Directive (EU) 2023/970 fast approaching, the latest status update shows a fragmented picture across the EU. As of 20 May 2026, only Slovakia and Italy appear to be the first Member States to have adopted comprehensive implementing legislation. Many others remain at draft stage or have yet to publish any legislation at all.
The overall position is striking. Two Member States are essentially complete, four have partial measures already in force, ten have published draft legislation, and eleven still have no public draft available. Belgium is among the countries with partial implementation in force, although this is currently limited to public-sector measures, with no private-sector federal draft yet published.
Next to the transposition by Italy and Slovakia, the main update since April 2026 is that Latvia and Romania now also have a draft text for their transposition.
One of the clearest themes emerging from the draft texts is the risk of “gold-plating”, where national rules go beyond the minimum standards required by the Directive. We identify Lithuania and Poland as the clearest examples at this stage. Lithuania’s draft is particularly far-reaching: it would impose remuneration-policy obligations on all employers, require monthly pay and working-time reporting through social-security channels, and remove size-based exemptions. Poland, by contrast, follows a more literal approach overall but adds tighter procedural requirements, including a 30-day deadline for responses to pay information requests and a fixed annual notice date of 31 March.
Other Member States are also considering broader national choices. The Netherlands would strengthen works-council rights and extend scope to temporary agency workers. France would lower the reporting threshold from 100 to 50 employees, while Denmark would expand coverage for employers with 50–99 employees through a statistics-based model. Ireland and Italy would also go further on pre-employment transparency by requiring more detailed pay information in job advertisements.
The political and legislative outlook remains challenging. Recent reporting suggests that no extension of the transposition deadline is currently expected. We therefore anticipate that only two Member States will implement on or close to the deadline, and that several countries—at least ten—could face infringement proceedings unless legislative processes accelerate significantly.
In short, while momentum is building, Europe is heading toward the deadline with significant divergence in both timing and substance. For employers operating across multiple jurisdictions, the key takeaway is clear: preparation should not wait for full national implementation, and special attention should be paid to countries where gold-plating may materially expand compliance obligations.
