Takeaways

• While Czechia’s restrictions on employer-imposed pay secrecy are already in force, its broader implementing framework remains under development, with implementation currently targeted for 01.01.27 and certain obligations expected to be phased in from 2028 to 2031.
• Employers should review confidentiality provisions and related employment documentation now.
• The partial measure does not appear to “gold-plate” the EU Pay Transparency Directive materially, although the broader draft legislation should be monitored for additional country-specific requirements.

Related links

• EU Pay Transparency + Uneven Member State Adoption: Four Points for Multinational Employers
• EU Pay Transparency Transposition: Poland Rolls Out Local Recruitment Requirements as Broader Framework Emerges

Article

Czechia has taken a different path from Poland’s approach to partial implementation of the EU Pay Transparency Directive 2023/970. Czechia’s recruitment transparency requirements are already in force while broader legislation remains under development.

Poland has adopted the full recruitment and reporting framework as its first step. Czechia’s initial partial transposition has taken the form of a single employee transparency protection: Employers may not prevent employees from disclosing information concerning their own compensation.

The pay-secrecy prohibition was not introduced as a stand-alone transposition measure. It was adopted as part of a broader Labour Code amendment, the “...

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