Takeaways

• Transposition activity continues as EU Member States advance draft legislation and move toward adoption.
• Several countries are nearing implementation, making significant progress.
• Employers should prepare now despite varying timelines and country-specific implementation differences.

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EU Member States’ uneven adoption and implementation of Directive (EU) 2023/970 on pay transparency is forcing employers operating in multiple EU jurisdictions to track national developments closely.

By the June 7, 2026, deadline only Italy, Lithuania, Malta, and Slovakia completed transposition of the EU Pay Transparency Directive. Greece recently finalized its transposition.

Importantly, while timelines have slipped, governments across Europe continue to advance draft legislation. In addition, public consultations have concluded in many jurisdictions, and a number of countries appear to be entering the final stages of their legislative processes.

For multinational employers, this means the compliance landscape continues to evolve rapidly.

Countries Nearing the Finish Line

While the timing of final adoption will vary from country to country, the reality is that many countries are expected to enact implementing legislation over the coming months (in most cases, by the end of 2026 or in 2027).

Jurisdictions making significant progress include:

• The Netherlands: Draft legislation has progressed through the advisory process, and implementation is expected to...

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