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. |
| Germany | Existing gender pay reporting requirements: Yes - 500+ employees reporting on measures but not pay gap percentage. Consistent with the Directive: No - additional obligations required. |
| 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 |
