At a Glance
- While Slovakia, Malta, and Italy enacted comprehensive laws implementing the EU Pay Transparency Directive (PTD) by the June 7 deadline, most other member states did not. This continues to create a fragmented implementing landscape across Europe.
- Private employers should be aware of several practical considerations created by a member state’s missed deadline, including loss of grace periods, potential court Directive-friendly interpretations, and increases in worker and worker representative inquiries.
- Even though Austria, Germany, and Ireland have not proposed specific implementing legislation, there are nuanced local risks to consider.
The deadline is here – yet in many places, implementation is still not in sight
The implementation deadline for the EU Pay Transparency Directive (PTD) has now passed, yet full national transposition remains uneven across member states. Although governments were required to transpose the EU Pay Transparency Directive into national law by June 7, 2026, many European countries have only taken partial steps.
Member states currently fall into three categories:
- Adoption of Comprehensive Legislation: Slovakia, Malta and Italy have adopted comprehensive legislation, meeting the transposition deadline. These laws have minimal or non-existent grace periods. Lithuania, Poland and Czech Republic have partially transposed the Directive.
- Published Draft Legislation: Several countries have published draft legislation but either...
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