Brussels: The Pay Transparency Directive reached its transposition deadline on 7 June 2026, and only four of the 27 member states had completed the job in full and on time. Slovakia, Italy, Lithuania and Malta made it, according to a tracker updated on 12 June and reported by Remote Work Europe. The other 23 capitals now face the infringement procedure that the Commission says it will open.

Where the Pay Transparency Directive stands

Directive (EU) 2023/970 entered into force on 6 June 2023 and gave governments three years to write its rules into national law. The deadline therefore fell on 7 June 2026. The tracker shows a patchwork rather than a single picture of delay. The Netherlands, Sweden, Czechia and Denmark have confirmed a start on 1 January 2027, while Ireland, France, Finland and Poland have announced delays. Germany and Spain had no draft legislation at the time of the update, and Belgium has formally asked for a six-month extension.

That last request sits awkwardly with the Commission’s stated position that no extensions will be granted. A directive sets a binding date, and nothing in EU law lets a government move it by asking politely. The request is best read as a signal of how much preparation remains.

What the rules demand from employers

The Pay Transparency Directive gives job applicants the right to know the pay range for a role before an interview, and it bars employers from asking about previous salary. Workers can request information on average pay levels, broken down by gender, for colleagues doing the same work. The aim is to make unequal pay visible so that it can be challenged and corrected.

Reporting duties arrive later and in stages. Employers with 250 or more workers must report on calendar year 2026 by 7 June 2027. Companies with 150 to 249 workers start reporting from the same date, then every three years, while firms with 100 to 149 workers follow from 7 June 2031. A gender pay gap of 5% or more that cannot be justified triggers a joint pay assessment with workers’ representatives.

How infringement could unfold

The Commission’s tool is the infringement procedure. It begins with a letter of formal notice, which usually gives a government two months to respond. A reasoned opinion follows, with a further two months. If the state still has not acted, the Commission can refer the case to the Court of Justice of the EU and ask for financial penalties.

There is a recent precedent. Spain was fined €6.83 million, plus a daily penalty, for missing the transposition of the Work-Life Balance Directive. That case shows that the Pay Transparency Directive is not a soft target, although the process is slow. Cases usually take years, and the sums depend on a state’s size and the length of the delay.

Why late transposition hurts companies too

Delay in applying the Pay Transparency Directive does not spare employers from preparing. Multinational groups must plan for 27 national versions of one text, and some will be stricter than others. Where a member state has not legislated, firms face uncertainty about job-advert wording, pay-band structures and the data they need to collect during 2026 for the first report.

Workers face a different problem. Where a state has no national rules, the Pay Transparency Directive may give some rights directly against public employers, but enforcement against private companies is far harder. Equality bodies and unions will therefore watch which capitals move quickly and which wait for formal notices.

What happens next

Three signals deserve attention in the coming months. First, whether the Commission opens infringement cases against all 23 states at once or sequences them. Second, whether the large economies, Germany above all, table credible drafts. Third, whether the Gender Equality Strategy 2026-2030, adopted on 5 March 2026, becomes the vehicle for fresh pressure on laggards.

The Pay Transparency Directive was designed to turn a principle into an enforceable right. With only four capitals ready on the deadline, the 2027 reporting date now looks like the real test, and the credibility of the directive will rest on how many governments have caught up by then.