Welcome to our update on the EU's Pay Transparency Directive (the PTD).
As we move towards the PTD's implementation date of 7 June 2026 we will keep you informed about key changes across the EU member states as they roll out the Directive at a local level.
The PTD seeks to close the gender pay gap and harmonise pay transparency across the EU.
The PTD must be transposed into national law by member states by 7 June 2026 which must put in place minimum rules set out in the PTD and stakeholders will have to comply as soon as national law is in force.
All employers will be required to comply with pay history, setting, information and pay confidentiality requirements. However, depending on the size of their workforce, some organisations may have until 2027 or 2031 to comply with the PTD's wider gender pay gap reporting measures.
The PTD represents a sweeping change for employers and the staggered transposition of the PTD suggests the regime is complex. Many member states are considering how to apply the measures, with some having incorporated aspects of the PTD into national law already. However, Member states are currently awaiting guidance from the European Commission, and it is hoped this will clarify some of the more complex aspects of the PTD.
Current status of PTD in key EU jurisdictions
| EU Member state |
Implementation status |
Expected implementation |
| Austria |
No draft published. |
June 2026 and June 2027 |
| Belgium |
Partially implemented for pay transparency in the public sector of the French community. |
June 2026 and June 2027 |
| France |
Draft legislation proposed undergoing government review. |
February 2026 |
| Germany |
No draft published. |
June 2026 and June 2027 |
| Ireland |
Draft legislation proposed on pay transparency. |
June 2026 and June 2027 |
| Netherlands |
Draft published/delayed implementation date until 2027. |
Late implementation January 2027 |
| Poland |
Draft published and partially implemented for pay transparency. |
Partial implementation 2025 with implementation June 2026 and February 2027 |
| Spain |
No draft published. |
June 2026 and June 2027 |
Latest changes:
Poland – on 24 December 2025 Polish legislation came into force prohibiting employers enquiring about pay history and mandating that employers inform applicants of starting pay or salary ranges in advertisements or at the latest before the interview.
Countries to watch:
Germany – 7 November 2025 saw Germany's pay transparency commission publish recommendations on implementing the PTD. Draft legislation transposing the PTD is expected in 2026.
Poland – 16 December 2025 Poland published a draft Act seeking to implement other provisions. The Polish government also published a draft tool to assist employers with evaluating the value of roles (downloadable here). Feedback for the tool closed on 9 January 2026.
As always, if you have any questions about the PTD generally or about matters in a particular member state, we would be happy to assist you with these.
