Takeaways

• With the EU Pay Transparency Directive 06.07.26 transposition deadline nearing and Member States’ uneven implementation, multinational employers will be required to track country-specific rules.
• Employers must comply with core transparency obligations, including gender-neutral pay structures, providing pay ranges during recruitment, and responding to employee pay information requests within set timeframes.
• The Directive introduces pay gap reporting and remediation requirements, with varying obligations by employer size.

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The transposition deadline for EU Member States to have implementing measures in force for Directive (EU) 2023/970 on pay transparency is June 7, 2026, and the EU Commission has made clear no extensions will be granted. With only Italy and Slovakia having passed full final transpositions, most countries are expected to miss the deadline, resulting in uneven implementation across the European Union.

Employers operating in multiple jurisdictions should therefore track national developments closely.

Four key points warrant particular attention.

1. Gender-Neutral Pay Structures Are Mandatory

Employers’ pay structures must enable an assessment of whether workers are performing the same work or work of equal value. Those structures must be based on objective, gender-neutral criteria and must not directly or indirectly discriminate based on workers’ sex. At minimum, the assessment criteria must include skills, effort,...

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