EU Pay Transparency Directive: overview across jurisdictions
Published on 1st October 2025
Below you will find a summary of the impact of the Directive on different Member States in relation to pay transparency and gender pay reporting obligations. For a more detailed look at each jurisdiction, please click on the jurisdiction links.
The Directive's pay transparency requirements
| Belgium | Existing pay transparency requirements: Limited (CBA no. 25 and CBA no. 38, moral guidelines). Consistent with the Directive: No - additional obligations will need to be implemented. |
| France | Existing pay transparency requirements: Limited (general non-discrimination principles only). Consistent with the Directive: No - additional obligations will need to be implemented. |
| Germany | Existing pay transparency requirements: Yes (non-discrimination principles, information rights for employees in companies with greater than 200 employees). Consistent with the Directive: No - additional obligations will need to be implemented. |
| Italy | Existing pay transparency requirements: Yes (non-discrimination principles, some reporting). Consistent with the Directive: No - additional obligations will need to be implemented. |
| The Netherlands | Existing pay transparency requirements: Limited (only non-discrimination principles). Consistent with the Directive: No - additional obligations will need to be implemented. |
| Poland | Existing pay transparency requirements: From December 2025 pre-employment transparency obligations in place. Consistent with the Directive: Yes from December 2025 in respect of pre-employment transparency obligations. Additional obligations will need to be implemented in respect of the other Directive requirements. |
| Spain | Existing pay transparency requirements: Some (salary register and job evaluation and non-discrimination). Consistent with the Directive: Partially but additional obligations will need to be implemented. |
| UK | Existing pay transparency requirements: Limited (non-discrimination principles). Consistent with the Directive: N/A |
The Directive's pay reporting requirements
| Belgium | Existing gender pay reporting requirements: Yes - all employers annual audit; 50+ employees (concise report); 100+ employees (comprehensive report). Reporting every 2 years. Consistent with the Directive: No - additional obligations required. |
| France | Existing gender pay reporting requirements: Yes - 50+ employees (lighter reporting annually); 250+ employees (full reporting every 3 years). Consistent with the Directive: No - additional obligations required. The draft bill introduces a reformed reporting framework based on the Directive's seven indicators, applicable to companies with 50 or more employees, with detailed tiered obligations by company size and a June 2030 deadline for the seventh indicator for companies with fewer than 150 employees. |
| Germany | Existing gender pay reporting requirements: Yes - 500+ employees reporting on measures but not pay gap percentage (Pay Transparency Act 2017). Consistent with the Directive: No - additional obligations required. The November 2025 Advisory Commission report recommends the reporting threshold be set at 100 employees under implementing legislation, not including companies with 50 to 99 workers, based on actual payroll data of the previous year. A draft law is expected before the implementation deadline in June 2026. The Advisory Commission recommends the right to information should only apply for the first time in 2027, but it is unsure if the Ministry will follow this route. |
| Italy | Existing gender pay reporting requirements: Yes - 50+ employees. Reporting every 2 years. Consistent with the Directive: Partially - alignment needed. |
| The Netherlands | Existing gender pay reporting requirements: No Consistent with the Directive: Obligations will need to be implemented. |
| Poland | Existing gender pay reporting requirements: No Consistent with the Directive: Obligations will need to be implemented. |
| Spain | Existing gender pay reporting requirements: Yes - all companies (salary register); 50+ employees (equality plan and audit). Consistent with the Directive: No - alignment needed. |
| UK | Existing gender pay reporting requirements: Yes - 250+ employees (annual reporting). Consistent with the Directive: N/A |
