Pay Transparency Directive implementation in May 2026: Different timelines and national approaches
The EU Pay Transparency Directive (“Directive”) is in the implementation phase, but the timetable across the member states remains uneven. While the Directive must be transposed into national laws by June 7, 2026, recent updates show that several countries are adjusting their legislative schedules, and in some cases reconsidering the pace and scope of implementation. This difference seems to reflect the varying degrees of readiness and different attitudes towards the topic among national labor market systems and stakeholders.
This blog post is an update across Fondia’s operating countries as of early May 2026, highlighting where each jurisdiction stands in its implementation process. As the country-specific overviews below demonstrate, the range of national responses is notable: from active legislative proceedings to calls for postponement and renegotiation of the Directive at the EU level.
Finland
The implementation of the Directive will be delayed.
In Finland, the government has indicated that the legislative proposal is nearing completion, with an updated timeline pointing to submission to Parliament in mid-June 2026. While delays have been acknowledged, the government’s overall direction remains clear: Finland is proceeding with implementation rather than seeking to pause or renegotiate the Directive. At the same time, the final entry into force of national legislation will be delayed and the new target date has not yet been confirmed. According to the government, the postponement reflects ongoing discussions with labor market parties and the broader complexity of the reform.
Sweden
The implementation of the Directive has been suspended.
A legislative proposal was expected to be presented by the Swedish government in March 2026. Shortly after a sudden postponement of the implementation of the Directive to January 2027, the government declared on March 26 that it does not intend to present a proposal at this time due to the administrative burden it would impose on the employers. Instead, the government intends to work towards an overall postponed implementation and renegotiation of the Directive in Brussels.
Estonia
The implementation of the Directive has been postponed.
Although the gender pay gap has been one of Europe’s highest in Estonia, the Estonian government announced on April 16, 2026, that it is seeking a two-year postponement of the Directive’s entry into force and requesting its revision, citing the administrative burden it would impose on companies. At the same time, the government has stated that it fully supports the Directive's underlying aim of reducing gender discrimination and the pay gap, and plans to incorporate certain provisions into domestic law, including the applicant's right not to disclose current or previous salary and the obligation to inform about the salary range of the position being applied for. The decision has drawn criticism, including from the Gender Equality Commissioner, and the broader debate reflects tensions between deregulation ambitions and employee rights.
Lithuania
The implementation of the Directive is proceeding on time.
In Lithuania, amendments to the Labour Code and four accompanying legislative acts have been submitted to the Parliament with a view to transposing the Directive into national law by June 2026. The proposed amendments aim to establish a pay transparency mechanism, including the right of employees to obtain information about their pay and to compare it with the pay of employees in equivalent roles through institutions such as the Labour Inspectorate, Labour Disputes Commissions and trade unions. The Committee on Social Affairs and Labour has been designated as the lead committee, with further parliamentary discussion scheduled for 19 May.
Summary - Directive's obligations for the employers
As a reminder, below is a summary of the key employer obligations established by the Directive, which member states are required to transpose into their national laws. Beyond compliance, meeting these obligations is also an opportunity to build trust, strengthen employer branding, and improve employee retention.
All employers:
When recruiting, employers must proactively disclose the starting salary or salary range in job postings or before the interview and must not ask applicants about their current or previous salary. Job titles and postings must be gender neutral.
Employers must provide employees with information on the objective, gender-neutral criteria used to determine pay, and must not prohibit employees from disclosing their own salaries (any such contractual clause is void).
Upon request, each employee is entitled to receive, within two (2) months, their individual pay level and the average pay levels by gender for equivalent roles. Employees must be informed annually of this right.
Employers with 50 or more employees:
Employers must also inform employees of the objective, gender-neutral criteria used to determine pay development.
Employers with 100 or more employees:
Employers must report the gender pay gap to designated domestic public institutions (every three years for 100–249 employees; annually for 250+). If reporting reveals an unjustified gap of ≥5% in any employee group that remains uncorrected after six (6) months, a joint pay assessment must be conducted with employee representatives and delivered to employees, their representatives, and the national Ombudsman for Equality within 12 months. Any unjustified gaps identified must then be corrected within a further six (6) months.
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This blog post is a part of a series focused on the implementation of the EU Pay Transparency Directive across Fondia’s operating countries. In the other parts, we will take a closer look at specific aspects of the Pay Transparency Directive from different national perspectives, addressing key questions in a practical and hands-on way.
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