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Spain has published its long-awaited draft Royal Decree to partially transpose the EU Pay Transparency Directive. While the proposal appears to go beyond certain aspects of the Directive and under-implements others, the direction of travel is clear, and employers should begin their preparations now.

After a summer of missed transposition deadlines, leaked drafts and speculation, Spain has finally published its draft Royal Decree. Released on 3 August 2026 and open to public consultation until 24 August 2026, the draft aims to partially transpose the EU Pay Transparency Directive. Although Spain’s draft Royal Decree is unlikely to take effect as early as the end of August 2026 – theoretically the earliest possible ‘go-live’ date had been 25 August - employers with operations in Spain should prepare for a potentially very short runway before new national obligations take effect.

In this article, we examine what employers need to know about Spain's draft Royal Decree and the steps they should be taking now to prepare.

Spain's existing pay transparency framework

Spain already has a relatively well-developed equality and pay transparency framework. It is built on the Workers’ Statute and Royal Decree 902/2020 on equal pay for women and men. Article 28.2 of the Workers’ Statute requires all companies to maintain a pay register covering their entire workforce. Additionally, employers with 50 or more employees must prepare and apply an equality plan every four years, unless...

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