EU Pay Transparency Directive: Recent Updates on National Implementation

In less than a year, the deadline for implementing the EU Pay Transparency Directive is approaching. Two countries, Malta and Poland, have recently enacted legislation addressing specific elements of the Directive, while the Netherlands has proposed a bill to implement the directive. France is also in the early stages of implementation, with discussions ongoing on how to transpose the Directive into national law.

Key Takeaways:

• Malta introduced legislation on June 27, 2025, requiring employers to provide job applicants with salary ranges before employment, and workers to request their own pay and the pay of "categories of workers" performing the same work.
• Poland enacted an Act on December 24, 2025, which will inform candidates of their starting remuneration or wage brackets, and provide candidates with information on any specific company rules on remuneration.
• The Netherlands proposed a bill in March 2025, which will require employers to provide transparency about renumeration prior to employment, gender-neutral job-titles, and prohibit asking about salary history during discussions on employment terms.
• Employers with 50 employees must provide employees with access to the criteria used to determine wage development, and companies with 250 employees or more must report annually on pay differences between men and women.
• France is holding discussions on implementation of the Directive with trade union and employer representatives, aiming to finalize a dedicated bill by the Autumn and enact the law in December 2025.

Statistics:

• 27 June 2025: Malta introduced legislation to satisfy certain aspects of the Directive.
• 24 December 2025: Poland's Act partially implementing the Directive will come into force.
• 3 September 2025: France's discussions on implementation of the Directive with trade union and employer representatives will conclude.
• By Autumn 2025: France aims to finalize a dedicated bill on implementing the Directive.
• By December 2025: France aims to enact the law on implementing the Directive.
• By February 2026: France will examine and publish implementing decrees.
• 50 employees: Employers must provide employees with access to the criteria used to determine wage development.
• 250 employees or more: Companies must report annually on pay differences between men and women.
• 100-249 employees: Companies must report every three years on pay differences between men and women.

Sources:

• Malta's legislation (no date provided in source)
• Poland's Act (partially implementing the Directive, no date provided)
• The Netherlands' proposed bill (March 2025)
• France's Ministry of Labour discussions (no date provided, ongoing discussions)