Pay transparency in the EU: implementation status and national particularities

Belgium has not yet completed a full federal transposition of Directive (EU) 2023/970. However, certain elements of the directive have already been partially implemented for parts of the public sector, particularly at the regional level, with applicability beginning on 1 January 2025. In this context, recent discussions within the parliamentary committee for social affairs confirm that the transposition process is still ongoing. Authorities are reviewing both existing collective bargaining agreements and national legislation to identify areas requiring further implementation. The process is also linked to the BE Magic initiative, which runs until the end of 2027 and examines the directive’s impact on the existing legal framework.

Belgium already has an established legislative framework on equal pay, particularly through the Anti-Discrimination Act of 10 May 2007 and the Act of 22 April 2012 on reducing the gender pay gap. The latter introduced company-level monitoring and reporting obligations, mainly applicable to medium-sized and large private-sector companies, although it does not cover the public sector or a significant proportion of small businesses.

Existing legislation defines remuneration broadly, including gross salary and all related benefits and advantages, but it does not impose a legal obligation to establish pay scales or formal job-classification systems. Instead, it focuses on reporting mechanisms and social dialogue. Employers with at least 50 employees must prepare a statistical report every two years on pay differences between women and men, structured by occupational categories. This report must be discussed within the works council or, where none exists, within the committee for prevention and protection at work. Companies with at least 100 employees face more detailed reporting requirements, including breakdowns by remuneration types and benefits.

In parallel, the 2022 Act on transparent and predictable working conditions already imposes certain salary information obligations, including communication of base salary, salary components, benefits and payment methods before or at the start of employment.

Until a full transposition is adopted, the existing national framework remains the primary regulatory instrument, in the context of Belgium’s obligation to align with Directive (EU) 2023/970. Enforcement is mainly carried out by the labour inspectorate, and failure to comply with reporting obligations may result in administrative sanctions.

With an estimated gender pay gap of approximately 0.7%, Belgium remains one of the countries with the lowest gender pay disparities, illustrating the effectiveness of a regulatory framework based on periodic reporting, social dialogue and institutional intervention, even without complete implementation of the directive.

The Czech Republic proposes one of the most comprehensive and technically detailed transpositions of Directive (EU) 2023/970, reflecting both the country’s relatively high gender pay gap and the legislator’s preference for deep structural reform.

The scope is broad, covering both public and private sectors, including temporary workers, workers engaged under agreements outside standard employment contracts (DPP/DPČ) and certain public-service categories, without explicit exclusions. The draft provides for the new framework to apply from 1 January 2027, postponing implementation of certain obligations compared with the directive’s timetable.

A central element of the transposition is the obligation for employers to establish a formal pay system documented through internal regulations or collective agreements. This system must include job grouping according to the value of work, based on objective and gender-neutral criteria reflecting factors such as skills, effort, responsibility and working conditions, in alignment with criteria already contained in the Czech Labour Code regarding complexity, responsibility and difficulty of work.

Remuneration is defined broadly, in line with the directive, encompassing base salary, variable pay components and benefits in cash or kind. Temporary agency workers must be paid according to the pay system of the user undertaking during the assignment.

During recruitment, employers must inform candidates, in a verifiable manner, about the minimum remuneration level and other monetary benefits before contractual negotiations begin. Requests for salary history are prohibited. Criteria for determining remuneration and benefits are integrated into mandatory internal systems and must be accessible to employees.

Reporting mechanisms combine employer obligations with a centralised model administered by the Ministry of Labour and Social Affairs (MPSV). Gender pay gap reporting is mandatory for employers with at least 100 employees. Employers with fewer than 100 employees may voluntarily opt in, allowing the ministry to generate employer-level reports based on administrative data without imposing additional detailed reporting obligations.

The first reporting exercise is scheduled for 2028 using 2027 data, representing approximately a one-year delay compared with the directive, which envisages reporting beginning in 2027 for 2026 data.

If reports indicate an unjustified pay difference of at least 5% within a job category that is not corrected within six months, employers must conduct a joint pay assessment involving employee representatives.

The sanctions regime is severe. Fines may exceed €41,000 (CZK 1,000,000) for serious violations of transparency and assessment obligations. Victims may claim full compensation, including non-material damages, without any upper limit.

With an estimated gender pay gap of approximately 18.5%, one of the highest among the countries analysed, the Czech approach represents an example of extensive and coercive implementation aimed at correcting deeply rooted structural inequalities.

Denmark starts from an already functional framework for pay transparency, built upon the Equal Pay Act (Ligelønsloven) and a strong tradition of social dialogue.

The draft applies the European concept of “worker” broadly, covering all persons in an employment relationship without explicit exclusions for part-time workers or other contractual arrangements. Remuneration is defined extensively and includes base salary/minimum wage as well as all other forms of pay and benefits, such as bonuses, overtime payments, mobility benefits and education and training allowances. No explicit exclusions apply to variable pay components.

Regarding pay-system architecture, the draft does not require a single model such as a national salary grid. Instead, the state must ensure the availability of tools and methodologies for job evaluation and classification that support objective and gender-neutral comparisons, while responsibility for compliance remains primarily with employers.

Transparency is strengthened from the recruitment stage. Candidates have the right to receive information regarding the initial pay level or salary range and this information must be provided in the vacancy notice or through other means before the interview. It cannot be postponed until after salary negotiations or contract signing.

Employers are prohibited from requesting salary history.

Within organisations, employers must make available to workers, in an easily accessible format, the criteria used for determining pay levels and pay progression. For individual information requests, employers must respond without undue delay and no later than two months.

Regarding reporting, the draft follows the directive’s thresholds. Employers with fewer than 100 workers currently have no obligation to report gender pay gaps and Denmark has not chosen to extend reporting obligations below this threshold.

The accuracy of reported data must be confirmed by management. Information may be reviewed by the Danish Working Environment Authority (Arbejdstilsynet), the Danish Institute for Human Rights and a designated monitoring authority, all of which may request clarifications and explanations.

Corrective obligations arise when unjustified pay differences are identified. A joint pay assessment becomes mandatory when:

• the difference is at least 5%;
• the difference remains unjustified; and
• it has not been corrected within six months after the report is submitted.

Worker representatives have a strong procedural role. Consultation and cooperation are mandatory and joint assessments require active participation, although they do not entail joint decision-making authority over pay.

The sanctions regime must be effective, proportionate and dissuasive. It may include administrative fines, civil liability (compensation) and structural or organisational orders. Repeated violations may result in additional consequences, such as exclusion from public funding or procurement procedures, although specific fine amounts have not yet been established in the draft.

Victims are entitled to full compensation, including retroactive pay differences, bonuses, benefits, material damages and non-material damages, without any cap.

Despite this robust institutional framework, an estimated gender pay gap of approximately 14% indicates the persistence of structural disparities, suggesting that transparency and reporting are necessary but not always sufficient without substantial intervention in evaluation and pay-progression criteria.

Finland integrates the requirements of Directive (EU) 2023/970 into an already well-established national framework on equal treatment, applicable to both the public and private sectors, without explicit exclusions for atypical forms of work. The scope covers employees under employment contracts and other comparable working relationships, including temporary workers, in line with Finnish equality legislation.

Remuneration is defined broadly, consistent with both the directive and national law, including base salary, variable pay components and benefits in cash or in kind. Employers are required to establish gender-neutral pay structures, documented through job-classification systems, objective evaluation criteria, internal policies and collective agreements, enabling the identification and correction of unjustified pay disparities.

Transparency is ensured from the recruitment stage through the obligation to communicate the starting salary or salary range before hiring and through the prohibition on requesting salary history. During employment, employees have the right to access information regarding pay-setting criteria and progression mechanisms. Employers must respond in writing within two months to requests concerning individual remuneration and average pay levels broken down by gender.

Where direct disclosure could lead to identification of individuals, information must be provided through employee representatives or the Equality Ombudsman.

Finland applies a hybrid reporting model. Employers with at least 30 employees must prepare a gender equality plan that includes a pay survey. The reporting obligations introduced by the directive apply from the threshold of 100 employees, with reporting frequency varying according to organisational size.

If an unjustified pay gap of at least 5% is identified, employers must implement corrective measures and conduct a joint pay assessment within six months, involving trade unions or employee representatives.

The sanctions regime is significant. Failure to comply with pay-assessment obligations may result in fines ranging from €5,000 to €80,000 and the burden of proof generally rests with the employer. Compensation for pay discrimination is determined case by case and covers both material and non-material damages without a statutory cap.

Enforcement is carried out by the Equality Ombudsman, the Equality Tribunal and the courts, within a system strongly integrated with sectoral collective bargaining.

With an estimated gender pay gap of approximately 16.3%, Finland demonstrates that advanced transparency and oversight mechanisms do not automatically eliminate pay disparities, but they provide robust institutional tools for identifying and systematically addressing them.

France already had an advanced framework on equal pay, based on the recognition of the concept of work of equal value and on monitoring pay disparities through standardised indicators.

The transposition of Directive (EU) 2023/970 seeks to integrate European requirements through a substantial reform of existing mechanisms, including the replacement of the current “Professional Equality Index” with an expanded set of pay-transparency indicators.

The concept of “work of equal value” is already firmly established in French legislation and is based on criteria such as professional competence, experience, responsibilities and physical or mental demands. It is now being expanded to include soft skills and working conditions.

Job classification for assessing work of equal value is primarily established through company-level or sectoral agreements. In their absence, it is determined by the employer following mandatory consultation with the Social and Economic Committee (Comité Social et Économique - CSE).

Transparency begins at the recruitment stage. Job advertisements must include the proposed salary range and relevant provisions of applicable collective agreements. Where no formal vacancy notice exists, this information must be provided in writing before or during the interview.

Employees are entitled to compare their remuneration not only with colleagues within the same company but also with employees in other companies covered by the same collective agreement, significantly broadening the comparison framework.

Reporting obligations vary according to company size.

Employers with 50-99 employees must inform the Social and Economic Committee about pay indicators, methodologies used and results. Any disparities identified must be addressed through negotiation or through a unilateral equality action plan.

Employers with at least 100 employees face additional consultation obligations and significant pay disparities must be justified or corrected within six months. Remaining disparities are addressed through joint assessments and corrective measures reported to authorities.

The sanctions regime is strict. Violations of key professional equality obligations - including reporting, consultation and implementation of corrective measures - may result in fines of up to 1% of total payroll, with increased penalties for repeat offenses.

For other infringements, fines may reach €450 per incident.

In pay-transparency disputes, the burden of proof lies entirely with the employer. Most of the new transparency indicators will be published through the Ministry of Labour, emphasising the reputational consequences of non-compliance.

With an estimated gender pay gap of approximately 11.8%, France occupies a middle position between countries with very low disparities and those with pronounced structural gaps, illustrating a model in which extensive transparency and public pressure play a central role in correcting inequalities.

Ireland had already established the principle of equal pay for equal work or work of equal value through the Employment Equality Act, as well as a basic framework for reporting gender pay gaps through the Gender Pay Gap Information Act 2021.

However, implementation of Directive (EU) 2023/970 remains largely under development, with many key elements not yet reflected in national legislation.

Currently, gender pay gap reporting is mandatory for employers with more than 50 employees, regardless of sector and covers both base salary and variable compensation such as bonuses.

This mechanism operates independently from formal pay structures. Employers are not currently required to adopt salary grids, job-classification systems, or standardised job-evaluation tools. Responsibility for organising and justifying pay practices therefore remains largely with individual employers.

Unlike the directive, current legislation does not impose general pay-transparency obligations during recruitment. Employers are not required to disclose salary levels or salary ranges to candidates and remain free to decide whether to publish such information in job advertisements.

Similarly, employees' access to information regarding pay-setting criteria, salary progression and deadlines for responding to individual requests is not explicitly regulated.

Enforcement mechanisms also remain limited. Gender pay gap reporting relies primarily on employer self-reporting, without systematic auditing or external inspection mechanisms. The way in which data accuracy will be verified and the exact role of public authorities remain undefined.

The Irish Human Rights and Equality Commission (IHREC) is currently the principal body responsible for enforcing existing legislation through monitoring and compliance assessments. However, the complete enforcement architecture required by the directive has yet to be established.

Likewise, mechanisms concerning pay-gap remediation, involvement of trade unions or employee representatives and sanctions for non-compliance remain “to be determined.”

Although existing legislation allows compensation for pay discrimination, such compensation is currently subject to statutory caps. How these limits will be adapted to comply with the directive’s requirement for full compensation remains unclear.

Ireland has confirmed that it will not meet the original transposition deadline and intends to implement the directive gradually.

The first measures are expected to address recruitment transparency, followed later by employee information rights, reporting obligations and joint pay assessments.

In its current form, the Irish framework provides a foundation for transparency but does not yet incorporate the structural, procedural and enforcement mechanisms required by Directive (EU) 2023/970.

With an estimated gender pay gap of approximately 8.3%, Ireland ranks among countries with relatively small pay disparities. However, future developments will depend largely on how comprehensively and rapidly the new European obligations are implemented.

Italy places National Collective Labour Agreements (CCNLs) at the center of the assessment of equal work or work of equal value. These agreements constitute the official and mandatory framework for evaluating pay structures.

Assessment of work of equal value is based on objective and gender-neutral criteria established in the CCNLs - skills, responsibility, effort and working conditions - creating a presumption of compliance when these classifications are correctly applied.

Employers may use internal job-evaluation systems only as a supplementary tool and cannot replace or contradict CCNL classifications.

The Ministry of Labour may issue additional guidance by 31 December 2026 regarding practical evaluation methodologies.

Pay-transparency measures apply to all employees in both the public and private sectors, including part-time workers, fixed-term employees and managers. Certain specific categories are excluded, including apprentices, domestic workers, casual/on-call workers, temporary agency workers and self-employed individuals.

Remuneration is defined more narrowly and structurally than in many other jurisdictions, focusing on gross annual salary and gross hourly equivalents while excluding discretionary, temporary, or non-structural individual payments.

During recruitment, employers must communicate the starting salary or salary range either in job advertisements or, at the latest, before contractual negotiations begin. Requests for salary history are prohibited.

Throughout employment, workers have the right to access information regarding remuneration criteria, salary progression and their own pay data, as well as average pay levels broken down by gender. Employers must respond in writing within two months of a request.

Gender pay gap reporting obligations apply only to employers with at least 100 employees, following the thresholds and frequencies established by the directive:

• Annual reporting for employers with more than 250 employees.
• Reporting every three years for employers with 100-249 employees.

If unjustified pay disparities of at least 5% are identified, employers must implement corrective measures and conduct a joint pay assessment within six months, following consultation with worker representatives, whose role remains advisory.

Italy does not create new enforcement or sanction mechanisms, relying instead on existing structures.

Oversight is exercised by:

• The National Labour Inspectorate (INL).
• Equality Councillors.

These bodies may request documentation, conduct inspections and intervene in cases of non-compliance.

Victims of pay discrimination are entitled to full compensation without statutory limits, including material and moral damages, together with corrective measures designed to eliminate discriminatory practices.

With an estimated gender pay gap of approximately 5.3%, relatively low compared with many Member States, Italy illustrates a model in which collective bargaining and existing institutional frameworks play the primary role in ensuring pay equality. However, the effectiveness of increased transparency depends heavily on the consistent application of CCNL classifications and on the enforcement capacity of existing institutions.

Lithuania adopts a model strongly focused on pay transparency and administrative intervention, emphasising centralised monitoring and the rapid correction of unjustified pay disparities.

Employers are required to include salary information in all job advertisements and requesting candidates’ salary history is prohibited.

During employment, employees may submit pay-transparency requests and employers must respond within a reasonable period not exceeding two months. Information may be provided directly to employees or, where privacy concerns arise, through employee representatives or equality bodies.

A distinctive feature of the Lithuanian model is the automatic publication of gender pay gap data. The public social insurance system (SoDRA) annually publishes average salaries by gender for each company, largely eliminating individual employer reporting obligations and significantly reducing administrative burdens.

Where an unjustified pay difference of at least 5% is identified, employers must implement corrective measures within six months, in cooperation with employee representatives, the Labour Inspectorate, or equality bodies. If disparities persist, a joint pay assessment becomes mandatory.

Consultation with trade unions and employee representatives is particularly encouraged in matters relating to job classification, dispute resolution and collective bargaining.

Failure to comply with transparency or remediation obligations may result in administrative fines ranging from €400 to €6,000, particularly where unjustified pay differences meet or exceed the statutory 5% threshold.

The system is further supported by clear government guidance concerning thresholds and remediation timelines.

With an estimated gender pay gap of approximately 10%, Lithuania illustrates a model in which pay transparency is primarily achieved through automated administrative tools, producing a visible, though moderate, impact on reducing gender pay disparities.

Malta transposes Directive (EU) 2023/970 by amending its existing framework on transparent and predictable working conditions, adopting a pragmatic approach focused on rapid implementation.

The new obligations are introduced through amendments to the Transparent and Predictable Working Conditions Regulations, enacted under the Employment and Industrial Relations Act (Cap. 452) through Legal Notice L.N. 112 of 2025.

This mechanism allows the rules to enter into force within two months of publication in the Official Gazette.

Recruitment transparency is ensured through the obligation for employers to provide candidates, before employment begins, with information regarding the starting salary or salary range applicable to the position, as well as relevant collective agreement provisions.

This information may be included in job advertisements or communicated no later than before negotiations on the individual employment contract.

However, the draft does not expressly prohibit employers from requesting salary history from candidates.

Malta’s approach is characterised by minimal additional regulatory intervention. It largely integrates the directive’s requirements into existing legislative structures without creating new reporting, enforcement, or sanction mechanisms specifically related to pay transparency.

This strategy favours rapid and formal compliance but raises questions regarding the framework’s ability to generate structural changes in pay practices.

With an estimated gender pay gap of approximately 4.9%, one of the lowest among the countries analysed, Malta’s experience should be interpreted cautiously, given the relatively small size of its labour market and the limited level of institutional intervention provided by the new regulations.

The Netherlands adopts a complex and layered approach to implementing Directive (EU) 2023/970.

The framework applies to workers in both the public and private sectors who are in an employment relationship under Dutch law. It follows the directive’s broad concept of “worker” and explicitly includes temporary agency workers, while self-employed individuals remain outside its scope.

No specific exclusions are provided for part-time employment, fixed-term contracts, or statutory leave arrangements.

Remuneration is defined broadly and includes base salary, all variable pay components and benefits in cash or in kind associated with employment, such as:

• bonuses;
• commissions;
• overtime premiums;
• pension contributions.

Expense reimbursements are excluded.

Employers must establish gender-neutral pay structures and job-evaluation systems based on objective criteria, including:

• skills;
• effort;
• responsibility;
• working conditions.

These structures may be established through collective agreements (CAOs) or internal policies. However, Works Councils (Ondernemingsraad - OR) possess consent rights regarding key elements under the Works Councils Act (WOR).

Recruitment transparency requires employers and intermediaries to provide salary information or salary ranges, together with relevant collective agreement provisions, before salary negotiations begin.

Requests for salary history are prohibited.

During employment, workers are entitled to access information concerning remuneration criteria, salary levels and career progression. Information may be provided through written policies, internal documentation, or collective agreements, with Works Council involvement where appropriate.

Employers must respond in writing within two months to employee requests regarding their own remuneration and average pay levels by gender for equal work or work of equal value.

Gender pay gap reporting obligations apply from the threshold of 100 employees, in accordance with the directive.

A multi-level verification system ensures accuracy:

• Management must confirm the data after consultation with the Works Council.
• A national monitoring body collects and publishes key indicators.
• The Labour Inspectorate may request documentation and verify compliance.

Where reporting identifies an unjustified pay difference of at least 5% in a category that remains uncorrected after six months, employers must conduct a joint pay assessment with employee representatives and implement corrective measures within a reasonable period.

Worker representation is central to the Dutch model. Works Councils must be consulted and possess consent rights regarding evaluation criteria and corrective measures, while trade unions perform this role where collective agreements apply.

Enforcement combines administrative and civil mechanisms.

The Dutch Labour Inspectorate may:

• issue warnings;
• impose compliance orders;
• levy administrative fines.

Fines may reach approximately €10,300 per violation and inspection outcomes may be made public.

In parallel, victims of pay discrimination may seek full compensation through the courts without any statutory cap. Once an indication of discrimination or a transparency violation has been established, the burden of proof shifts to the employer.

Implementation is governed by the draft law Wet implementatie Richtlijn loontransparantie mannen en vrouwen.

Dutch authorities have indicated that implementation will occur after the European deadline, with entry into force targeted for 1 January 2027.

With an estimated gender pay gap of approximately 11.2%, the Netherlands represents an intermediate model characterised by strong oversight mechanisms and substantial employee participation, while remaining dependent on effective enforcement and institutional capacity.

Poland uses Directive (EU) 2023/970 as a catalyst for strengthening a coherent pay-transparency framework within a labour market characterised by flexibility and decentralisation.

The scope of the legislative proposal is broad, covering virtually all employees within the meaning of the Labour Code, regardless of working time or contract type, including temporary workers.

No single national job-classification system is established. Responsibility for assessing comparability of work rests primarily with employers.

Remuneration is defined broadly and includes all salary elements:

• base salary;
• variable pay components;
• monetary benefits;
• non-monetary benefits related to employment.

The April 2026 draft requires employers to establish transparent pay structures that enable comparison of work of equal value based on the four directive criteria:

• skills;
• effort;
• responsibility;
• working conditions.

Although no single mandatory tool, such as a national salary grid, is imposed, employers must in practice implement job-classification systems or remuneration policies that allow meaningful comparability assessments.

Trade unions and employee representatives participate in establishing criteria and reviewing pay structures.

Poland partially transposed certain recruitment-transparency requirements in December 2025 through amendments to the Labour Code.

Employers must communicate the starting salary or salary range to candidates no later than the interview stage or before concluding the employment contract.

Requests for salary history are prohibited.

During employment, employees may request information regarding:

• their own remuneration;
• average gender-disaggregated pay levels for comparable positions;
• salary-setting criteria;
• career progression criteria.

Employers must generally respond within 30 days.

Periodic gender pay gap reporting applies to employers with at least 100 employees. Smaller employers are exempt from reporting obligations but remain subject to individual transparency requirements.

Information regarding pay disparities by employee category must be proactively made available to employees and their representatives.

If unjustified pay differences are identified, employers must implement corrective measures within six months.

Oversight involves several public authorities:

• National Labour Inspectorate (PIP);
• Ombudsman for Equal Treatment;
• Central Statistical Office;
• courts.

Administrative penalties may exceed €14,000 (PLN 60,000) and are not linked to company size or turnover.

Victims of pay discrimination are entitled to full compensation without any maximum limit, including:

• salary adjustments;
• lost benefits;
• interest;
• compensation for additional harm resulting from unequal treatment.

With an estimated gender pay gap of approximately 4%, one of the lowest in the European Union, Poland illustrates a model where relatively low pay disparities coexist with flexible regulation based on employer responsibility and active involvement of social partners. However, the absence of a standardised national job-evaluation framework means that effectiveness depends heavily on consistent application and enforcement.

Romania proposes an extensive transposition of Directive (EU) 2023/970, explicitly applicable to all workers in the public and private sectors, including civil servants, military personnel and other categories regulated by special laws.

The definition of remuneration is broad and includes any gross remuneration in the form of base salary, allowances, bonuses, supplements and other additional payments, including complementary or variable components received directly or indirectly for work performed.

Employers must ensure that all remuneration components, including variable pay and benefits in cash or in kind, are based on transparent, objectively justified and gender-neutral criteria.

In the public sector, salary grids are mandatory.

During recruitment, employers must provide candidates with information on the initial salary or salary range, based on objective and gender-neutral criteria, as well as applicable collective agreement provisions. This information must be included in the job advertisement or communicated in writing before the interview.

During employment, workers must have easy access to information on criteria used to determine remuneration, pay levels and salary progression mechanisms, where these exist. Employers with fewer than 50 workers are exempt from the obligation to provide information on salary progression criteria.

Employers must respond to individual requests for pay information within a maximum of 30 working days. They must also inform all workers annually, by the end of the first quarter, about their right to access salary information and the steps required to exercise it.

Gender pay gap reporting applies to employers with at least 100 workers. Employers below this threshold may report voluntarily.

Reported data must be confirmed by the employer after consultation with employee representatives. Reports are submitted to ANES, and workers, representatives, labour inspectorates and CNCD may request clarifications.

Where pay differences cannot be justified by objective and gender-neutral criteria, employers must remedy the situation within 90 working days, in cooperation with employee representatives and competent authorities. In justified cases, this period may be extended, but not beyond six months.

Romania also adopts a broad comparison framework. Comparability is not limited to workers employed by the same employer or during the same period. It may include remuneration elements established by law or collective agreements at group, sectoral, national, or parent-company level.

Where no direct comparator exists, other evidence may be used, including statistical data or hypothetical comparative analyses.

Violations are punishable by fines ranging from RON 10,000 to RON 20,000, and repeated violations may lead to fines of RON 20,000 to RON 30,000.

Victims of pay discrimination are entitled to full compensation without a maximum cap, including unpaid salary rights, lost benefits, moral damages, interest and other relevant losses.

With an estimated gender pay gap of approximately 3.7%, Romania ranks among the countries with the lowest gender pay disparities, although this indicator should be interpreted cautiously in light of labour-market structure and occupational segregation.

Slovakia stands out in the European Union as the first Member State to have finalised transposition of Directive (EU) 2023/970 and to have committed to meeting the implementation deadline of 7 June 2026.

Slovakia introduces a detailed pay-transparency framework, mainly applicable to employment relationships governed by labour law, with certain explicit exclusions.

The legislation does not apply to public officials holding public office or statutory-body positions, nor to certain categories of public-sector personnel performing management functions under appointment or election procedures established by law.

Remuneration is defined broadly and includes base salary, minimum wage, remuneration under work agreements outside standard employment relationships and other monetary or in-kind benefits forming additional remuneration components.

Employers must establish remuneration structures ensuring transparency and enabling the evaluation of equal work or work of comparable value based on objective criteria.

Work evaluation is based on criteria that are not directly or indirectly gender-dependent, including complexity, responsibility, workload, working conditions and other relevant factors, such as social and communication skills.

During recruitment, employers must provide candidates with information on initial remuneration or the initial remuneration range, based on objective criteria, as well as applicable collective agreement provisions. The obligation is met if this information is included in a published job advertisement.

During employment, employers must provide employees with criteria used to determine remuneration, pay levels and salary increases. Employers with fewer than 50 employees are exempt from the obligation concerning salary-increase criteria.

Employers must provide requested information within two months.

Employers with fewer than 100 employees are not subject to mandatory reporting but may voluntarily submit remuneration reports to the Ministry of Labour.

Employees, their representatives, the labour inspectorate and the Slovak National Centre for Human Rights may request additional clarifications and employers must respond with reasons within 30 days.

Where pay differences cannot be justified by objective criteria, employers must take corrective measures in cooperation with employee representatives. A joint remuneration assessment must be carried out within six months.

If no employee representatives exist, employees may appoint ad hoc representatives with employer support.

A relevant feature of the Slovak framework is the broader comparison possibility: comparisons are not limited to employees of the same employer and may include situations where remuneration conditions are determined by a common source.

The Ministry of Labour must publish analytical tools and methodologies for assessing comparable work by 30 June 2026.

Failure to comply with reporting obligations first leads to a compliance deadline set by the Ministry of Labour. Failure to meet that deadline may result in fines between €4,000 and €8,000. For other violations, the labour inspectorate may impose sanctions of up to €100,000.

Employers may not request candidates’ previous remuneration and must annually inform employees of their right to access pay information.

Affected people are entitled to full compensation without explicit limits.

Slovakia’s framework illustrates a complete and structured implementation model, focused on operational mechanisms and practical enforceability. However, with an estimated gender pay gap of approximately 15.7%, its effectiveness will depend heavily on consistent application, monitoring and enforcement.

Sweden integrates the directive into an already mature framework based on the Swedish Discrimination Act (Diskrimineringslagen 2008:567) and annual pay audits (lönekartläggning), mandatory for employers with headquarters and more than 10 employees.

In principle, all categories of workers in the labour market fall within equal-pay obligations, except consultants employed by other companies and individuals operating their own companies.

Remuneration is defined very broadly and includes all gross salary components and benefits granted to employees, including RSU and stock-option schemes. Depending on implementation, certain items such as one-off bonuses or travel allowances and expenses may be excluded from calculations.

During recruitment, there is no obligation to include salary in job advertisements. However, candidates must be informed in good time before deciding whether to accept an employment offer.

Employers are prohibited from asking candidates about current or previous salary.

A central element of the Swedish model is the broad right to information. All employees may request information regarding salary structure and salary ranges for a particular branch or function.

Employers must respond in writing within two months and must inform employees at least annually about the existence of this right and the procedure for exercising it.

Documentation and reporting obligations vary by company size:

• Companies with up to 25 employees must verify pay transparency but do not need written documentation.
• Companies with 25-100 employees must document transparency.
• From 100 employees, reporting to the Equality Ombudsman (DO) is required every three years.
• Companies with more than 250 employees must report annually.

In addition, employers with 26-100 employees must document pay discrepancies of around ±5%, without a reporting obligation. If discrepancies are not remedied within six months, the issue must be addressed with trade unions and reported to the Equality Ombudsman.

Trade unions and worker representatives have a substantial role. They must review, participate in, and validate pay-transparency information and its accuracy, reflecting Sweden’s social-dialogue and collective-bargaining model.

Swedish legislation does not set fixed fine thresholds or standard amounts. Enforcement relies on compliance orders, firm deadlines, and conditional fines (vite).

Although there are no major “headline” fines, legal risk remains significant because employees may claim uncapped civil compensation, including:

• retroactive salary;
• bonuses;
• variable pay components;
• lost pension contributions;
• interest for the retroactive period.

Sweden has expressed reservations about the directive’s administrative complexity and the government intends to postpone implementation until January 2027, without removing the substantive obligations.

With an estimated gender pay gap of approximately 11.2%, Sweden continues to show persistent gender pay disparities despite its mature regulatory framework and established salary-audit mechanisms. This highlights the limits of purely preventive approaches without further structural intervention.