News · 19 October 2026

Pay Transparency Directive in October 2026: five complete national laws, bills before five parliaments, and the 2027 reporting calendar unchanged

By Mihai Postolache, founder of Egalis · Updated 19 October 2026

In short

Four months after the transposition deadline of 7 June 2026, five member states have complete implementing laws for Directive (EU) 2023/970 — Italy, Slovakia, Lithuania, Malta and Greece — and Estonia, Poland and Belgium have transposed parts of it. In October the work moved into the parliaments: Bulgaria's lead committee approved its bill on 1 October, Denmark tabled its bill for application on 1 March 2027, Czechia opened its first reading on 16 October, and Romania's Senate rejected its draft on 14 October, leaving the final decision to the Chamber of Deputies. The Commission's infringement packages up to 1 October 2026 contain no proceedings on 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.

The five complete laws: what changed in October

Greece: Law 5316/2026 (Government Gazette A' 105, 6 July 2026) applies its substantive obligations from 1 November 2026. The Ministry of Labour's circular 26923 of 7 October 2026 sets out how: every employer needs written pay structures from 1 November 2026, the ministry reads the first reference period as 1 November to 31 December 2026, and the first reports go to the Ombudsman [Συνήγορος του Πολίτη] by 7 June 2027 from employers with 150 or more workers, each legal entity reporting separately. The ministerial decisions on the amount of fines and on the Ombudsman's reporting platform are still to be issued.

Lithuania: the Labour Code amendments (Law No. XV-969) have applied since 7 June 2026, with reporting through the state social insurance fund Sodra from 1 January 2027. Sodra has published the structure of the new monthly report (SDUP) and, on 13 October 2026, its questions and answers: employers file monthly through Sodra's employer portal, and Sodra computes and publishes hourly pay by sex where a group has at least eight workers, including at least four men and four women.

Slovakia: Act No. 76/2026 Coll. has applied since 7 June 2026, and the deadline for every employer's pay structure passed on 31 July 2026. On 2 October 2026 the Ministry of Labour [MPSVR SR] published an updated version of its job-evaluation tool. The first reports to the ministry are due by 7 June 2027 from employers with 150 or more employees, for the period 1 August to 31 December 2026; afterwards, reports are due by 15 April each year.

Italy (Legislative Decree No. 96/2026) and Malta (Legal Notice 173/2026) have applied their laws since 7 June 2026.

Bills before parliament

Bulgaria: the bill amending the Protection against Discrimination Act, tabled on 11 September 2026, was approved unanimously at first reading by the lead human-rights committee on 1 October 2026; the plenary first vote is pending. The bill makes the Commission for Protection against Discrimination the monitoring body and the recipient of the reports.

Czechia: the government bill (Chamber of Deputies print 300) entered its first reading on 16 October 2026. Two opposition parties moved to reject it — mainly over the unemployment-benefit cuts bundled into the same package — and the reading was adjourned. The bill proposes most obligations from 1 January 2027 and the reporting and information rights from 1 January 2028.

Denmark: the government tabled its bill in the Folketing's opening week in October 2026, with the rules to apply from 1 March 2027. France: the government bill was filed at the Senate on 10 September 2026 under the accelerated procedure.

Romania: the Senate, the first chamber, rejected the draft law L445/2026 on 14 October 2026 (27 for, 1 against, 62 abstentions). The Chamber of Deputies decides definitively, starting from the initiators' text: bill Pl-x 682/2026, amendments by 28 October and the committee report by 5 November 2026.

Drafts and plans

Croatia: the Ministry of Labour confirmed on 13 October 2026 that it is preparing amendments to the Labour Act; according to public broadcaster HRT (18 October 2026), the draft goes to public consultation in the week of 19 October, and the new rules would apply from February 2027.

Poland: the recruitment rules have applied since 24 December 2025; the main bill (UC127) is a government draft, with adoption by the Council of Ministers planned for the fourth quarter of 2026. From 5 November 2026, a separate amendment to the Labour Code (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 a new Article 18³ᶠ.

Hungary: the government's autumn legislative programme planned to table a bill in September 2026; as of 19 October 2026 the bill has yet to reach parliament. Germany, Ireland, Luxembourg and Sweden remain at an early stage.

Infringement: no proceedings on the Directive so far

The Commission's infringement packages of 15 July, 25 September and 1 October 2026 contain no letters of formal notice on Directive (EU) 2023/970. The July letters concerned the directives on standards for equality bodies (2024/1499 and 2024/1500). The Commission has also confirmed that the Directive and its reporting calendar remain unchanged.

What it means for employers

The Directive's calendar holds across the EU: employers with 150 or more workers report on 2026 by 7 June 2027 in every member state with a complete law, and it is the reference everywhere else. Job evaluation, categories of work of equal value and complete 2026 pay data are needed under every national variant, and 2026 closes in ten weeks.

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

Sources

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