Quick Hits
- EU member states Estonia, Malta, Lithuania, and Slovakia have released recent updates on their respective implementation of the EU Pay Transparency Directive.
- Delays are now expected for Estonia; meanwhile, Malta, Slovakia, and Lithuania are still on track to meet the 7 June 2026 deadline.
- The European Commission has previously stated that the date for implementation remains 7 June 2026.
Estonia
The Economic Affairs Minister for Estonia, Erkki Keldo, has declared that Estonia would rather pay a fine to postpone the EU’s pay transparency enforcement than increase the burden on national businesses. Keldo maintains that the reporting requirements of the EU Pay Transparency Directive will only increase the ‘administrative burden on entrepreneurs’ and, instead, the emphasis should be placed on explanatory work among employers and employees.
Following this statement, it can be assumed that Estonia will not meet the EU Pay Transparency Directive implementation deadline of 7 June 2026. No further updates have been confirmed at this time.
Lithuania
Lithuania remains on track to meet the 7 June 2026 deadline and has revised its draft legislation implementing the Directive. The Government approved an updated version on 18 March 2026. It is planned that the new requirements will become mandatory on 7 June 2026.
Under the current draft, each employer would be required to classify the jobs within their organisation into separate job categories based on the same or similar jobs and work of equal value using objective, gender-neutral criteria.
All employers, regardless of the number of employees, would be required to adopt a remuneration system and make a monthly submission of pay data to the State Social Insurance Fund Board (Sodra), specifically regarding their employees’ pay, working hours, and job categories. This data will subsequently be used to prepare gender pay gap reports.
If the draft is passed, from 7 June 2026, employees would have the right to receive information on their own average pay and that of other employees in the same job category, broken down by gender. Employers would also be prohibited from asking about a candidate’s pay history. Employers in Lithuania are already required to provide pay information in all job postings.
Malta
The Malta Employers’ Association (MEA) has made an official request to the government to postpone the transposition of the Directive. The MEA argues that, despite the rapidly approaching deadline, no draft of the Maltese implementing legislation has been published, leaving employers without the clarity needed to prepare for compliance.
The postponement would follow a growing number of EU countries that have announced delays with the June deadline. Sweden, for example, has already announced its intention to delay implementation and seek a renegotiation of the Directive, citing administrative burdens and insufficient flexibility in the current framework. The MEA aligns itself with these concerns, arguing that a postponement would allow time for a potential EU‑level review and for Maltese employers to prepare adequately once a draft law is available. If postponement goes ahead, Malta would join those countries awaiting the outcome of the requests and concerns raised at the European level. The MEA emphasises that such a move would not undermine the Directive’s goals but would instead ensure legal certainty and a more practicable implementation framework.
As of now, the European Commission has not issued any formal comment on the calls for postponement or review of the Directive. Member states requesting delays are awaiting clarity on whether the Commission will consider adjustments to the implementation timeline or framework.
Slovakia
Slovakia is at the forefront of transposition in line with the Directive’s deadline. The draft implementation text proposes a strict deadline: employers must have compliant pay structures in place by 31 July 2026, while the Ministry of Labour must publish analytical tools and methodologies by 30 June 2026. The text largely follows the Directive, with employers required to report pay data, grant employees the right to information, and ensure transparency during the recruitment process.
Employers with at least 150 employees must submit their first pay report by 7 June 2027, covering the period from 1 August 2026 to 31 December 2026.
For more information on employers’ obligations in Slovakia, please see our article of 15 April 2026, “EU Pay Transparency Directive Implementation in the Czech Republic and Slovakia.”
Staying Informed
Employers are encouraged to stay informed about the implementation process in their respective jurisdictions. Information and updates on the progress of the directive’s implementation across the European Union can be found using Ogletree Deakins’ Member State Implementation Tracker.
