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Early Adoption of the EU Pay Transparency Directive Shows Inconsistency

The EU mandates that member states incorporate the pay transparency directive into their national laws by June 2026. Global employers are keen to see if national laws will clarify some components in the pay report, among other concerns. Belgium, Sweden, Poland, Ireland, the Netherlands, and Finland are taking the lead, yet clarity remains sparse. Additionally, the diverse national approaches could increase the burden on employers operating across multiple countries. 

Poland's draft legislation does not mention gender pay gap report: Poland is aligning with the directive through amendments to the Labour Code, focusing on recruitment practices. The draft mandates gender-neutral language in job ads and prohibits inquiries about salary history. 

Ireland builds on existing gender pay reporting laws. 

  • Job ads must include pay rates or ranges, exceeding the directive's requirements. 

  • Employers with 50 or more employees need to publish information on their gender pay gap annually based on existing gender pay reporting laws.  

The Netherlands' draft closely mirrors the directive, currently under parliamentary review. 

Finland's draft proposal, published on May 16, 2025, aligns with the directive by requiring transparency in pay rates during recruitment and granting employees the right to request pay information. Furthermore, the proposal introduces gender pay gap reporting obligations for companies with 100 or more employees, implementing a phased approach. Companies with 150 to 249 employees must comply by 2027, and those with 100 to 149 employees by 2031. Noncompliance could result in fines ranging from €5,000 to €80,000. 

What's next: With new proposals on the horizon for 2025, multinational employers grapple with the challenge of aligning with diverse standards. HR Policy Global will continue to monitor this area, bringing updates and sharing best practices with our members. 

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Authors: Wenchao Dong

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