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Pay transparency tracker
This year, employers across the EU will face the new reality of mandatory transparent remuneration structures, new reporting obligations and easier enforcement for employees under the EU Pay Transparency Directive. Employers will need to establish transparent remuneration structures, explain pay gaps and be prepared to fulfil the reporting obligations.
Although the implementation of the Directive has been delayed across EU countries to meet the 7 June 2026 deadline, it is likely to be a matter of weeks or months before we see the respective national laws in the CEE/SEE region. It is expected that the national implementations will take effect without a grace period.
Our pay transparency tracker monitors the implementation status of the Directive in the EU countries of the CEE/SEE region.
Transposed
No country has completed transposition yet.
AUSTRIA
Information current as of 26 March 2026
Implementation status: Draft in preparation, not published yet.
Potential pitfalls in local implementation: N/A
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BULGARIA
Information current as of 5 June 2026
Implementation status: Draft published for public consultation on 19 May 2026; the consultation deadline has been extended to 18 June.
Potential pitfalls in local implementation:
The draft largely mirrors the main provisions of the Directive, including transparency during the hiring process, information rights, reporting obligations and joint pay assessments. The draft does not contain any provisions regarding enforcement rights, such as the shifting of the burden of proof or protection against retaliation. While the draft grants employee representatives a broad scope of powers (e.g. in relation to exercising employees’ information rights), it also does not address practical challenges for employers where no trade unions or employee representatives exist, which is typically the case for most Bulgarian companies. These shortcomings in the draft bill have prompted active public debate, with various stakeholders submitting comments and suggestions. This has led to an extension of the consultation period until 18 June and has delayed the planned vote on the draft bill, which was initially scheduled for 7 June.
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CROATIA
Information current as of 26 March 2026
Implementation status: Draft in preparation, not published yet.
Potential pitfalls in local implementation: N/A
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CZECH REPUBLIC
Information current as of 31 March 2026
Implementation status: A draft has been published and is going through the inter-ministerial commenting procedure.
Potential pitfalls in local implementation:
The draft Czech transposition act raises several conceptual and practical issues and leaves a number of points unclear for employers. The job evaluation criteria in the draft differ from those enumerated in the Directive. The Czech draft continues to rely on the existing list of criteria – which is exhaustive – and employers may not introduce any additional evaluation criteria beyond those expressly listed in the Labour Code . This rigidity could prove problematic in practice for employers seeking to justify pay differences on the basis of legitimate factors not captured by the currently applicable list of available criteria. Only high-level outlines of the method of calculating pay information and pay gaps have been published. The Ministry of Labour is still expected to provide further details. The draft transposes the “single source” concept from the Directive; however, it does not elaborate on how this principle is to be applied in practice.
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HUNGARY
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Information current as of 26 March 2026
Implementation status: No draft yet.
Potential pitfalls in local implementation: N/A
POLAND
Information current as at 8 May 2026
Implementation status: Certain provisions entered into force at the end of 2025. A second draft implementation law was published in May 2026.
Potential pitfalls in local implementation:
The second draft is more refined compared to the first version and addresses a substantial share of comments raised during public consultations. These include a delayed entry into force, a weaker role of trade unions and plans to provide a more detailed guidance on compliance with reporting obligations.
However, the draft still contains provisions that may raise interpretative concerns, particularly in relation to key definitions and the rules for comparing employees, including in the context of the “single source” principle, as well as the rules governing the disclosure and sharing of remuneration information with employees.
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ROMANIA
Information current as of 3 April 2026
Implementation status: Following a preliminary phase of more limited consultations with the business community (e.g. chambers of commerce and employers’ associations), the Romanian draft law transposing the PTD was published for public consultation on 30 March 2026. The draft reflects employer positions only to a limited extent. One aspect that was taken into account, for example, is the consistent use of the term “consultation” for all matters other than the social partners’ agreement on the criteria for qualifying and quantifying work of equal value. Romania appears to be adopting a minimal transposition approach, implementing the PTD largely as written and avoiding the introduction of extensive additional national requirements. Accordingly, the draft legislation signals a clear intention to avoid significant “gold‑plating.” At the same time, the draft partially departs from the Directive’s language and the practical implications of these deviations – particularly changes in concepts or terminology – remain to be assessed.
Potential pitfalls in local implementation:
A notable point of concern is the cross‑reference to Romania’s social dialogue legislation to determine the appropriate discussion partner for PTD‑related processes. This reference imports the existing hierarchical structure for collective bargaining – from representative trade unions down to elected employee representatives. Given that this cascade has been recognised as problematic in practice, particularly due to the prevalence of non‑representative trade unions compared to employee representatives (who, by definition, are elected by at least 50% plus one of employees), the current approach could complicate implementation of PTD obligations.
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SLOVAK REPUBLIC
Information current as of 26 March 2026
Implementation status: The commenting procedure has been completed; the consolidated draft is with the Slovak Parliament.
Potential pitfalls in local implementation:
The draft Slovak transposition law, in its current form, leaves a number of practical questions. Several key concepts remain broadly defined or insufficiently detailed, including the practical application of the “single source” concept and the treatment of situations where no employee representatives exist. Further, the law remains unclear on what happens when there is no agreement on criteria and the discussion takes place outside collective bargaining. The timeline is also notably tight – the Ministry of Labour’s methodologies are expected to be published by 30 June 2026, giving employers only one month before the compliance deadline of 31 July 2026. Much will therefore depend on the Ministry’s forthcoming guidance, which is still being developed and without which employers may find it difficult to comply in a meaningful and timely manner.
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SLOVENIA
Information current as of 26 March 2026
Implementation status: No draft yet.
Potential pitfalls in local implementation: N/A
