
Janne Malmisaari
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Published
13.04.2023
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Updated
02.10.2026
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14 min read
In short
The directive was formally adopted in May 2023, and EU member states had until 7 June 2026 to turn it into national law. Most of them missed the deadline, and employers across the EU are faced with numerous questions. What does this mean for employers? How will this affect recruitment and hiring processes? Continue reading to find out!
The EU Pay Transparency Directive is designed to level the playing field when it comes to salaries and recruitment. The directive dictates that:
Another major change is the reversal of the burden of proof. Once the new rules come into force, national legislation must require the employer, not the employee, to prove that no discrimination has taken place if cases are taken into court. The rules above will affect every company in the EU.
Additional requirements for reporting on the gender pay gap affect only larger companies. Companies with 250 or more employees need to report on the gender pay gap every year and companies with 150–249 employees every three years, starting in June 2027. Companies with 100–149 employees report every three years, starting in June 2031.
If the report shows a gender pay gap of at least 5% that the employer can’t justify or fix within six months, the employer must carry out a joint pay assessment with employee representatives.

The European Commission has made it clear that the deadline won’t be postponed at EU level. The national timetables still vary a lot. This is the situation as of October 2026:
| Country | Status | Planned start |
|---|---|---|
| Finland | Government bill HE 129/2026 vp submitted to Parliament on 9 July 2026 | 1 January 2027 (proposed) |
| Sweden | Government withdrew its proposal in spring 2026 and asked the Commission for changes | Not before 2027 |
| Denmark, Netherlands | Bills in preparation | 1 January 2027 (target) |
| Germany | Bill in preparation | 2027 (target) |
| Slovakia, Lithuania, Italy, Malta, Greece | Transposed in summer 2026 | 2026 |
In Finland, the Government’s bill proposes that the new rules take effect on 1 January 2027. Employers would have to give job applicants the starting salary or salary range early enough to allow a transparent salary negotiation, and employers with at least 100 employees would report their gender pay gap data through the Incomes Register.
In Sweden, the government withdrew its proposal in spring 2026 and asked the Commission for changes and more time. A new law isn’t expected before 2027. Meanwhile, Swedish employers with at least 10 employees still need to carry out an annual pay survey (lönekartläggning) under the Discrimination Act.
If you recruit in several EU countries, the safest bet is to build one transparent recruitment process that meets the directive everywhere.
Since you need to inform candidates about the salary range of your open vacancy before any interviews take place, you need to have a better grasp of the going rate for your open position.
The pay transparency directive might affect other HR processes more, but will have a major impact on recruitment as well. Since you need to inform candidates about the salary range of your open vacancy before any interviews take place, you need to have a better grasp of the going rate for your open position. If you have previously gauged a candidate's current or desired pay level during the salary negotiation, you will need to change your strategy.
You might end up alienating potential candidates by introducing a salary level that is too low, or on the other hand find yourself paying way over the market price. Sometimes you might end up in a situation where you want – or need to – offer a salary higher than you had originally planned to.
As you aren’t allowed to ask candidates about their salary history you need to implement other tactics during the salary negotiation. And about underpaying new hires. Well, it could backfire on you sooner than you think. An important factor to keep in mind is your new hire’s right to ask and receive information about the salaries of others working in similar positions at your company.
This may very well work the other way around as well: your current personnel might be interested to learn how much new hires are being paid and are their salaries in line. Some employers may have been using special terms in employment contracts to implement pay secrecy inside their organization.
This won’t be an option either in the future, so be sure to assess and correctly align your internal pay structures.
Pay transparency is often associated with forward-looking and fair employers. If you have a clear and equal pay structure, why not flaunt it to prospective talent?
While the new EU directive will level the playing field and force change, you can still find ways to differentiate and utilize pay transparency to your advantage, even if you haven’t been one of the forerunners in it. Pay transparency is often associated with forward-looking and fair employers.
If you have a clear and equal pay structure, why not flaunt it to prospective talent? One thing is for sure: job seekers want pay transparency. And preferably from the get-go by including it in the job description. According to a survey by LinkedIn, a whopping 91% of the survey’s respondents said that including salary ranges in a job post would directly affect their decision to apply.
Another one of their surveys showed that pay transparency in job postings would give a more positive impression of the company. Duunitori’s 2026 research in Finland echoed this sentiment: 84% of job seekers consider salary information important in a job ad. Yet only 7% of job ads on Duunitori showed the salary between January and July 2026.
Including the salary or salary range in your job ad creates trust among job seekers and could be the factor that tips the scales in favor of applying for your open vacancy. Pay transparency can be a powerful tool in your recruitment marketing. By answering these wants of the job seekers and employees you improve your employer brand and make sure you don’t miss out on quality applicants.
Want practical tips for including salary ranges in your job ads? Read our article Pay Transparency: Why And How You Should Implement It in Recruitment.
EU member states had to bring the directive into national law by 7 June 2026, but most missed the deadline, so the start date depends on the country. In the Nordics, Finland has proposed 1 January 2027 and Denmark is also aiming for the start of 2027, while Sweden has no bill yet and isn’t expected to have a new law before 2027.
The directive requires that applicants get the starting salary or salary range before the job interview. It doesn’t strictly require it in the job ad, but the ad is the simplest place to share it and the one candidates prefer.
The directive bans questions about salary history, meaning current and previous pay. It doesn’t ban talking about expectations, but since you’ve shared the salary range, the conversation should start from that range. Check the final national law for any stricter rules.
Yes, partly. The recruitment rules, the ban on pay secrecy and employees’ right to pay information apply to all employers. Gender pay gap reporting applies to employers with at least 100 employees, although individual countries can lower that threshold.
Employees who suffer pay discrimination have the right to compensation, including back pay. In a dispute, the employer must prove that there was no discrimination. Each country also sets its own penalties, such as fines.