The European Parliament and the Council of the European Union adopted Directive (EU) 2023/970, the EU Pay Transparency Directive, in 2023. Member states had until June 7, 2026 to transpose it. City AM reported on September 28, 2026 that only a handful transposed around that deadline.
Where does that leave UK-headquartered employers with EU staff? The UK isn’t bound by the directive, and its own equal pay proposals are at consultation stage only.
Where EU pay transparency transposition stands
Trusaic’s August 2026 tracker counts five full transposers, including Greece from July 2026. Sources: Trusaic, as of August 3, 2026, and the Ius Laboris tracker, updated October 5, 2026.
| Country | Status (as of source date) | Source |
|---|---|---|
| Italy, Slovakia | Transposed, as of October 5, 2026 | City AM, Ius Laboris |
| Malta | Transposed, as of August 3, 2026 | City AM, Trusaic |
| Lithuania | Transposed, as of August 3, 2026; right-to-information provisions apply from January 1, 2027 | Trusaic |
| Greece | As of August 3, 2026, law enacted July 2, 2026; substantive provisions apply from November 1, 2026 | Trusaic |
| France, Germany, Ireland, Spain | Draft (France, Spain) or initial steps (Germany, Ireland), as of October 5, 2026 | Ius Laboris |
The European Commission says it’ll give “particular attention” to whether national laws conform with the directive, so re-check each country first.
What the directive requires from employers
Directive (EU) 2023/970 sets an EU baseline, and national laws set the detail and start dates:
- Employers must share initial pay or its range before hire and can’t ask about pay history (Article 5)
- Workers can request average pay by sex for same or equal-value work, with a written reply within two months (Article 7)
- An unjustified category gap of at least 5%, unremedied after six months, triggers a joint pay assessment (Article 10)
- In pay discrimination claims, the burden of proof shifts to employers that haven’t implemented these duties (Article 18)
- Penalties must include fines (Article 23)
Article 9 gender pay gap reporting tiers:
| Workforce size | First report due | Frequency |
|---|---|---|
| 250 or more workers | June 7, 2027 | Every year |
| 150 to 249 workers | June 7, 2027 | Every three years |
| 100 to 149 workers | June 7, 2031 | Every three years |
June 2027 reports use 2026 pay data, and member states can extend reporting to smaller employers.
Why UK-headquartered employers are feeling the pressure
City AM notes many British companies employ staff across the continent. They may be subject to each member state’s rules, depending on how and where those staff are employed.
Rules differ by country. Amy Bird, a partner at Clifford Chance, told City AM: “Local guidance, detailed requirements and the level of gold-plating varies.”
The Office for Equality and Opportunity’s equal pay and pay discrimination consultation, published July 14, 2026, covers England, Scotland and Wales. It closes at 5pm on October 27, 2026 and proposes:
- Pay information in job ads, or in writing before interview
- An Equal Pay Regulatory and Enforcement Unit, its institutional home undecided
- A later phase broadly leveling up race and disability pay protections, keeping equal pay claims to sex
Bird told City AM that some options “mirror the provisions of the directive.” Under The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, employers with 250 or more employees already report UK gender pay gaps. Read our UK equal pay reforms update.
What employers can do now
Start with the baseline duties now:
- Audit pay bands and add ranges to EU job ads where required
- Remove pay history questions from EU hiring
- Check payroll can split 2026 average pay by sex and worker category
- Track each country’s effective dates and take local legal advice
Staying compliant across the UK and EU with Multiplier
With Multiplier’s Employer of Record (EOR), you can hire in 160+ countries without local entities. As the legal employer, we handle contracts, payroll, tax and benefits. Here’s what an Employer of Record does.
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Budget a hire with our employee cost calculator, read the UK country guide, see how we help you stay compliant, or book a demo.
FAQs
What is the EU Pay Transparency Directive?
It's Directive (EU) 2023/970, an EU law strengthening equal pay between men and women through pay transparency. It covers pre-hire pay information, a pay history ban, worker pay requests and gender pay gap reporting, applied through national law.
Which EU countries have transposed the directive?
Only a handful, as of early October 2026. City AM and Trusaic name Italy, Lithuania, Malta and Slovakia, and Trusaic adds Greece. Ius Laboris shows most others, including Germany and France, at draft or initial stages.
When do EU gender pay gap reports start?
Employers with 150 or more workers must report by June 7, 2027, using 2026 data. Employers with 100 to 149 workers start by June 7, 2031. National laws can set different dates, so check each country.
Does the UK have to implement the directive?
No. The UK isn't an EU member, so the directive doesn't apply there. But employers with EU staff may be subject to national rules, depending on how and where staff are employed. Take local legal advice.
How can an Employer of Record help with pay transparency?
An Employer of Record (EOR) employs staff under local law, so you can hire in the EU without your own entity. Multiplier's EOR covers contracts, payroll and benefits in 160+ countries. Confirm pay transparency duties with local counsel.
