The draft Bill implementing the Pay Transparency Directive for men and women was submitted to the Council of State for advice on 20 January 2026.

The draft Bill implementing the Pay Transparency Directive for men and women was submitted to the Council of State for advice on 20 January 2026. It is not yet known when this advice will be issued. What is clear, however, is that following the internet consultation and input from various advisory bodies, the draft Bill has been amended on several points.

These developments matter for employers, as the contours of the new obligations are becoming increasingly clear, as is the preparation that can already begin.

Background to the draft Bill

The draft Bill implements the European Pay Transparency Directive. Its objective is to reduce the gender pay gap by increasing transparency and strengthening enforcement.

What has changed following consultation and advice?

The explanatory memorandum has been clarified and expanded in several respects. In particular, it more clearly delineates what the Directive and the draft Bill do and do not regulate, and which matters are deliberately left open for further development in practice.

In addition, greater emphasis has been placed on privacy and data protection. The draft Bill now explicitly provides that pay information shared pursuant to the legislation may be used solely for the purpose of applying the principle of equal pay for equal or equivalent work. This requires employers to put in place...

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