Women in the EU earn on average 12% less per hour than men, according to Eurostat. To address this persistent gender pay gap, the EU is introducing new rules on pay transparency designed to strengthen the principle of "equal pay for equal work".
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For millions of workers, knowing the pay range before applying for a job can mean the difference between negotiating confidently and settling in the dark, afraid it could hurt employment prospects.
The directive could finally do away with the hush-hush culture around salaries — levelling the playing field for younger staff, returners from parental leave, and anyone who has historically been underpaid for the same role.
Under the Pay Transparency Directive, EU Member States are required to implement the legislation by 7 June 2026. However, progress across the Union has been slow, raising concerns that several countries could miss the deadline next year.
More recently, the Netherlands delayed the implementation of legislation according to PwC. The new expected implementation date is 1 January 2027.
“At the end of 2025, most EU countries are not yet ready with the implementation of the Directive and, in general, are progressing slowly,” Monika Krzyszkowska Dabrowska, head of employment practice in Addleshaw Goddard’s Warsaw office, told Euronews Business.
So, which EU countries are leading the way in implementing the Pay Transparency Directive, and how far along is the rest of the Union?
According to Addleshaw Goddard’s implementation tracker as of September 2025, 10 out of 27 countries have not yet taken any action toward implementing the directive. These include Austria, Bulgaria, Croatia, Denmark, Greece, Hungary, Italy, Latvia, Luxembourg, Portugal, and Slovenia.
In eight countries, draft legislation is expected. These include Cyprus, Czechia, Estonia, Finland, France, Romania, Slovakia, and Spain. This suggests that a technical committee or working group has been established, a proposal has already been prepared, and negotiations with stakeholders are currently underway.
In four countries, draft legislation has already been published: Ireland, Lithuania, the Netherlands, and Sweden.
Partial implementation is underway in three countries, namely Belgium, Malta, and Poland.
Germany is also preparing to update its act in line with the directive.
Adjusting the existing laws or introducing new ones
There are various approaches to implementation. Krzyszkowska-Dabrowska stated that some countries are adapting and adjusting existing laws — typically where national legislation already addresses requirements similar to those in the Directive — while others are introducing entirely new laws that closely mirror the Directive’s provisions, particularly where there is no comparable legal framework in place.
Dr. Duncan Brown, principal associate at the Institute for Employment Studies (IES), noted that the directive covers multiple aspects of pay transparency and applies to countries with diverse existing frameworks for ensuring equal pay.
Many countries have already implemented some elements, which explains the slower progress toward full compliance.
For instance, Austria has had a transparency initiative since 2011 and, according to Dr. Andreas Gulyas from the University of Vienna, only minor adjustments are needed to meet the new requirements.
Reasons for the lack of action or delays
“Although there do not appear to be specific groups openly opposing the Directive as such, its introduction carries significant weight for national laws and is often perceived as both revolutionary and problematic for employing entities,” said Krzyszkowska-Dabrowska.
It also imposes additional obligations on employers, grants new rights to employees — including a broader scope to bring claims — and increases the powers of courts and authorities.
She also pointed out that while the provisions of the directive are clear and highly technical, their practical interpretation and application present challenges.
“Collectively, these changes are set to reshape the legal landscape and introduce additional burdens, necessitating a systematic approach with various interrelated solutions,” she added.
Political turbulence hindering process
“Since the directive was passed in 2023, the political and economic volatility and crises that started with Covid ... have continued in this unstable and unpredictable decade,” Brown from the IES told Euronews Business.
He emphasised that, therefore, national governments have had other priorities on their agendas.
Issues include the war in Ukraine and the need to rapidly increase defence spending, widespread cost-of-living crises, and the rise of far-right populism with manifestos that are often anti-establishment and "anti-woke".
“All of this has meant that already busy legislative agendas have been severely stretched,” he added.
Current status in EU’s ‘Big Four’
Germany has not yet published a draft bill to implement the directive. The government set up an expert commission in July 2025 to prepare recommendations, with results expected by late autumn, according to Marijke van der Most, employment partner in Addleshaw Goddard’s German offices.
The delay is largely explained by Germany’s extraordinary political situation in 2025.
Following snap federal elections earlier this year, the country went through a full change of government. “This process temporarily interrupted the legislative agenda, as the new administration had to focus on coalition negotiations and immediate political priorities before returning to pending EU implementation matters,” she said.
She thinks that it remains realistic that Germany will meet the June 2026 transposition.
In France, a bill is expected in autumn 2025 following consultations with social partners, according to the Addleshaw Goddard tracker. No transposition activity has yet been reported in Italy.
Spain has already introduced obligations regarding pay transparency, such as the gender pay register for all companies and the gender pay audit for companies with 50 or more employees. The directive will require most organisations to review their pay models and define their remuneration policies in a much more precise manner.
Salary transparency in job postings is low
According to Indeed, salary transparency in job postingshas been steadily increasing across many countries, although the momentum has slowed in recent months.
The UK has the highest rate at 65% in May 2025, followed by France (48%), and the Netherlands (46%). Italy, Spain, and Germany find themselves at the lower end of the scale, with 25%.
While the UK continues to have the highest rate of pay transparency, the share of UK job postings including salary information has declined. In August, about 56% of job listings on Indeed included wage details, nearly 10 percentage points lower than at the start of the year.