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Sunday, May 17, 2026

From pay transparency to worker protections: Spain's latest employment law developments - A&O Shearman

Legislation updates

Pay transparency getting closer

The Government is progressing with the transposition into Spanish law of the European Pay Transparency Directive, which will require Spanish companies to abolish pay secrecy and comply with a new set of obligations, such as the disclosure of salary information from the recruitment stage, the review and objective justification of pay differentials, and regular reporting of pay gaps, in accordance with the applicable legal framework.

Failure to comply with these requirements may give rise to significant consequences, including administrative fines, liability for the full payment of unjustified pay differences, and exclusion from public procurement procedures.

How should companies act in relation to trans employees? New support protocol

This new protocol sets out the framework governing how a company must act where an employee initiates a gender transition process.

Among other obligations, employers are required to ensure full respect for the employee’s gender identity, adapt internal organizational arrangements (including identification documents, internal records and the use of workplace facilities), facilitate leave for medical appointments or administrative procedures, and safeguard confidentiality while preventing any form of discrimination.

Expanded options for hiring foreign workers

The new Immigration Regulation broadens the available pathways for employing foreign workers by allowing employment to commence from the...



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