EU: transposition of the Pay Transparency directive at a standstill in the majority of Member States

Adopted in 2023, the European pay transparency directive will require employers to shed light on their pay structures and apply gender-neutral criteria. The goal is to narrow the pay gap, given that for equivalent working hours, women’s average pay within the European Union (EU) remains 10.5% lower than men’s, according to our calculations based on the most recent data shared by Eurostat. For its part, the European statistical office reports a fairly similar average, weighted by the number of workers, at 11.1%. As of 7 June 2026, the deadline by which the 27 EU Member States were supposed to have transposed it, only four countries are on schedule: Italy, Lithuania, Slovakia, and Malta. Among the latter, only Italy had already implemented pay transparency mechanisms at the national level prior to the adoption of the European text. However, the country has opted for a minimalist transposition, limiting the number of information requests from employees and introducing a presumption of compliance with the directive as long as a company applies a national collective bargaining agreement. This choice aims to reduce administrative burdens for employers.

Nine other countries have started the transposition process, such as France, Romania, and Bulgaria, while others, like Germany, Spain, or Portugal, have not even submitted a draft bill yet. Although Spain and Portugal have launched consultations, Germany has even attempted to postpone transposition and renegotiate the directive’s content. “I think Germany may be ill-advised and will find itself isolated if it maintains this request. The European Commission has organized regular meetings to help Member States transpose this directive article by article,” states Isabelle Schömann, Deputy General Secretary of the European Trade Union Confederation. In addition, the European Institute for Gender Equality (EIGE) published a tool in March to help companies classify jobs into categories of equal value (to facilitate reporting and the right to information). “I am quite shocked to have heard the same demand from employers at our last meeting, saying it’s too complicated, it’s too expensive, we can’t do it, because they have been participating in these sessions for three years. Furthermore, challenging a directive that was democratically adopted three years ago amounts to challenging the rule of law,” Schömann denounces.

In addition to Germany, Greece followed Italy in introducing a presumption of compliance for companies covered by a collective agreement, while Czechia also acknowledges the minimalist nature of its draft transposition. Meanwhile, Belgium requested an additional six-month extension at the end of May 2026.