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Thursday, November 20, 2025

European Pay Transparency Directive: Implementation Challenges, Status, and Risks - Littler Mendelson P.C.

At a Glance

  • EU member states must transpose the EU Pay Transparency Directive into their national laws by June 2026, but the implementation process has been uneven.
  • This article discusses the status of the transposition process and the reasons for the delay, with a focus on Belgium, the Netherlands, and Norway.

All EU member states must transpose (or implement) European Directive (EU) 2023/970 on pay transparency (hereafter referred to as the “Directive”) into national legislation by June 2026 at the latest. Many countries already have rules regarding equal pay, gender-neutral job evaluation and classification systems, and reporting obligations, but the Directive requires additional steps and a more uniform approach.

Transposition is progressing slowly and unevenly across Europe, with varying reasons and challenges in each country. This article discusses why transposition is delayed in different countries (with a focus on Belgium, the Netherlands, and Norway), the current status of this process, and the risks associated with late transposition.

Why is transposition taking so long?

Belgium

According to the Organization for Economic Co-Operation and Development, Belgium is among the countries with the smallest gender pay gap in Europe.1 The principle of equal pay for all wage components, including classification systems, is firmly anchored in Belgian legislation, and reporting obligations already exist. Policymakers and social partners (i.e., employer representatives and...



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