With 12 months to go until the Pay Transparency Directive comes into force, we are starting to see steps being taken in some EU member states to prepare for its implementation. Progress is, however, still rather slow. This is not a reason for employers not to take action! We would continue to urge affected companies to be taking steps now to comply with the requirements of the Directive.
Previous experience with the Whistleblowing Directive suggests that many member states may not issue any draft legislation until late in the day, which means that if companies wait for local implementing legislation, they are unlikely to have sufficient time to ensure their business is compliant with the new obligations. Ensuring compliance is likely to require a great deal of work by most employers – this is not something you are going to be able to achieve in a few months. As the minimum requirements in the Directive are clear, employers should be able to use these as the framework for their preparations. It is also possible that local implementing legislation/guidance may not necessarily add much to what is already set out in the Directive, especially if member states seek to go no further than the minimum requirements set out there.
In the latest version of our “snapshot” guide, we have collaborated with our Global Edge contributors to set out the current state of play in 15 key EU member states, including an indication of the likely scale of change in different jurisdictions and the potential need for union/works council consultation along the way.
As the UK is no longer a member of the EU, it will not be required to implement the Directive. To the extent UK companies have operations in continental Europe, however, it will, of course, still be relevant. Greater transparency in pay practices and procedures in EU member states is also likely to raise the profile of this issue in the UK and potentially trigger demands from UK staff for similar information.
Please note that this guide is intended as a high-level overview only and should not be regarded as a substitute for legal advice. It sets out the position as of June 2025. We recommend that you always check the latest position with your local labour and employment lawyer. Where “/x” responses are given, they may be dependent on the facts and specific advice should always be taken.
