News · 2 November 2026

Pay Transparency Directive in November 2026: Greece's obligations apply from 1 November, Croatia's draft is in public consultation, and bills are before seven parliaments

By Mihai Postolache, founder of Egalis · Updated 2 November 2026

In short

On 1 November 2026 the substantive obligations of Greece's Law 5316/2026 took effect, so five member states now apply complete implementing laws for Directive (EU) 2023/970: Italy, Slovakia, Lithuania, Malta and Greece. On 2 November 2026 Croatia's Ministry of Labour presented its draft Labour Act amendments and opened the public consultation, which runs until 2 December 2026. Bills are before the parliaments of Bulgaria, Czechia, Denmark, Finland, France, the Netherlands and Romania: Denmark's bill L 68 had its first reading on 22 October, the Dutch bill is scheduled for a legislative consultation on 14 December, and Romania's Chamber of Deputies expects its committee report on 5 November. Poland's amendment on compensation for unequal treatment applies from 5 November 2026. The Commission has published no infringement package since 1 October 2026, and none so far concerns the Directive. The reporting calendar stays as the Directive sets it: the first reports, covering 2026, are due by 7 June 2027 from employers with 150 or more workers.

Greece: the obligations are in force

Articles 8–20 and 27 of Law 5316/2026 apply since 1 November 2026 (Article 48(2)). From that date every employer, whatever its size, maintains a written pay structure built on objective, gender-neutral criteria, tells candidates the starting pay or range before the interview, answers workers' information requests in writing within two months and informs staff of that right every year. For employers with 150 or more workers the first reference period runs, on the Ministry of Labour's reading in circular 26923 of 7 October 2026, from 1 November to 31 December 2026, with the indicators due to the Ombudsman by 7 June 2027, each legal entity reporting separately. The ministerial decisions on the amount of fines and on the Ombudsman's platform are still to be issued: a search of the Diavgeia transparency portal on 2 November 2026 returns none. Until then, breaches fall under the general labour-law range of €300–50,000 per breach.

Croatia: the draft is out, consultation until 2 December

On 2 November 2026 Minister Alen Ružić presented the draft amendments to the Labour Act [Zakon o radu] that transpose the Directive together with the platform-work directive, and the ministry published the draft and its impact-assessment form on the e-Savjetovanja consultation portal; both consultations run until 2 December 2026. According to the ministry and the press coverage of the presentation, employers apply objective criteria for job evaluation and pay, inform workers of their own pay and of the average pay of their category by sex, pay-secrecy clauses become void, and employers with more than 100 workers report on pay differences through a National Pay Transparency System that FINA will build for about €750,000, with reports generated from payroll data. Employers get at least six months after entry into force to adapt. The minister had announced the proposed fines on 22 October: up to €9,000 for the employer and up to €1,000 for the responsible person. After the consultation, the Government adopts the bill and sends it to the Sabor.

Bills before parliament

Denmark: bill L 68, amending the Equal Pay Act, was tabled on 8 October 2026 and had its first reading on 22 October 2026; it is with the Employment and Gender Equality Committee. The bill requires pay structures on objective, gender-neutral criteria, gives candidates and workers the pay information of the Directive, sets pay reporting for employers with 100 or more employees and for employers with 50–99 employees where a job function has at least eight of each sex, and creates a new Labour Market Institute for Equal Pay [Arbejdsmarkedets Institut for Ligeløn]. Proposed entry into force: 1 March 2027.

Finland: government bill HE 129/2026 vp, a new Act on Equality between Women and Men, has been before the Eduskunta since July 2026, with entry into force proposed for 1 January 2027; employers with at least 100 workers would report through the income register and Statistics Finland to the Equality Ombudsman, who supervises. In its statement of 11 September 2026 the Ombudsman asked for substantial changes during the parliamentary stage.

Netherlands: the implementing bill (36949) was submitted on 21 May 2026, amended by a note of amendment on 2 September and registered for plenary treatment on 8 September 2026; a legislative consultation [wetgevingsoverleg] is scheduled for 14 December 2026 and the plenary debate is pencilled in for week 50 of 2026 or week 2 of 2027. The government still aims at 1 January 2027, which leaves the date open.

France: bill n° 944 (2025-2026) was filed at the Senate on 10 September 2026 under the accelerated procedure; the Senate's file shows no committee or sitting date yet. Czechia: print 300 is with the Committee on Social Policy, which has not yet met on it; the second reading can start from 20 November 2026. Bulgaria: the bill amending the Protection against Discrimination Act remains in committee, with no plenary first vote; the labour committee received the opinions of the KNSB confederation on 20 October and of the Bulgarian Industrial Association on 26 October 2026.

Romania: at the Chamber of Deputies (bill Pl-x 682/2026), the human-rights committee gave a unanimous favourable opinion at its sitting of 27 October 2026, the deadline for amendments passed on 28 October, and the joint report of the labour, legal and equal-opportunities committees is due on 5 November 2026; the base text remains the initiators' form, after the Senate's rejection of 14 October.

Partial transposition and the rest

Poland: from 5 November 2026, the amendment published in the Journal of Laws 2026, item 1046, sets compensation for unequal treatment at no less than the minimum wage, at least three times that for multiple breaches, and writes the shifted burden of proof into the Labour Code; the main bill (UC127) remains a government draft, with adoption by the Council of Ministers planned for the fourth quarter of 2026. Lithuania: Sodra published on 13 October 2026 its rules for filling in and correcting the new monthly pay-transparency report (SDUP), which employers file from January 2027; every employer's pay system is due by 31 December 2026. Slovakia: Act No. 76/2026 Coll. applies unchanged. Hungary: the bill planned for September 2026 has still not reached parliament.

The Commission's infringement packages of 15 July, 25 September and 1 October 2026 contain no proceedings on Directive (EU) 2023/970, and no further package had been published by 2 November 2026.

What it means for employers

In Greece the obligations are live and the first reference period is running; in Croatia the consultation is the moment to comment on the draft; everywhere else the Directive's calendar holds: employers with 150 or more workers report on 2026 by 7 June 2027. Job evaluation, categories of work of equal value and complete 2026 pay data are needed under every national variant, and 2026 closes in eight weeks.

The pay gap calculator and the compliance calendar are free and run in your browser.

Sources

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