The overall picture as of 1 June 2026
A week before the deadline the EU position remains deeply uneven, but the past month has brought a marked acceleration. Lithuania adopted its act in May, Italy published a final text on 1 June, and Bulgaria published its own draft. At the same time, most Member States are still at preparatory consultation stage or have no published draft. As of 1 June 2026 the following groups emerge:
Clearest gold-plating signals
Gold-plating arises where a Member State imposes obligations on employers that go beyond the minimum standards set by the Directive. The clearest signals are visible in Lithuania, France, Ireland and Denmark. Partial gold-plating is also visible in Poland, the Netherlands and Italy. Bulgaria now joins this group: although the draft is framed as a minimum implementation, it does not exempt employers with fewer than 50 staff from pay-progression transparency, requires an automatic written justification to the enforcement body where a 5% pay gap is identified, and prefers fixed deadlines over the Directive’s more flexible “reasonable period”. Sweden remains a unique case: after publishing draft legislation in early 2026, the government announced on 26 March 2026 that it opposes the Directive and seeks renegotiation at EU level — the only Member State to have publicly withdrawn from the transposition process.
Country-by-country overview — all 27 Member States
The table below summarises the transposition status and the gold-plating signals for each Member State as of 1 June 2026.
| Member State | Transposition status | Gold-plating | Key points |
|---|---|---|---|
| Austria | No public draft | Not expected | No publicly reported preparatory work |
| Belgium | Partial in force | Not expected | Regional public-sector measures; federal private-sector draft pending |
| Bulgaria | Draft published | Gold-plating | Draft targeting the 7 June 2026 deadline. Framed as a minimum implementation but more onerous: no exemption for employers with fewer than 50 staff from pay-progression transparency; automatic justification to the enforcement body where a 5% gap is found; fixed deadlines; expanded role for the Commission for Protection against Discrimination |
| Croatia | No public draft | N/A | Advisory planning; spring 2026 activity expected |
| Cyprus | Draft published | Not expected | Consultation draft. Clean transposition; strong enforcement; focus on post-leave pay progression |
| Czech Republic | Partial in force | Not expected | Pay secrecy clauses banned from 1 June 2025; broader draft pending |
| Denmark | Draft published | Gold-plating | Consultation draft (26 February 2026). Reporting extends to 50–99 employees via statistics model. Implementation: 1 January 2027 |
| Estonia | No public draft | N/A | Preparation work under way |
| Finland | Draft published | Limited | Government denies any gold-plating intent, but existing equality-plan duties (30+ employees) layer on additional obligations |
| France | Draft published | Gold-plating | Draft of 6 March 2026. Threshold lowered to 50 employees (vs 100 in Directive). Penalty: up to 1% of payroll |
| Germany | No published draft | Not expected | The Federal Cabinet’s review, scheduled for 27 May 2026, did not take place. Now expected in June 2026, with the draft published around 20 June. “Bureaucracy-light” approach; threshold expected at 100 employees |
| Greece | No published draft | N/A | The Ministry of Labour has developed a draft (not yet published) after a consultation incorporating 65+ social-partner proposals. Thresholds: 250+ annually; 150–249 every three years; 100–149 every three years from 2031. Employers under 50 exempt from pay progression. Unlikely to meet 7 June |
| Hungary | No public draft | N/A | No public draft reported |
| Ireland | Draft published | Gold-plating | General Scheme 2024. Pay ranges required in job advertisements (not just before the interview). Website publication obligation beyond Directive |
| Italy | Act adopted (final text 01.06.2026) | Mixed | Final text published on 1 June 2026, identical to the recent draft, entering into force on 7 June 2026. Above minimum: pay structure in job ads; internal publication. Narrower: apprenticeships, domestic work, on-call excluded |
| Latvia | No public draft | N/A | No public draft published |
| Lithuania | Act adopted (May 2026) | Gold-plating (broadest) | Clearest GP jurisdiction. Split timeline: most requirements from 7 June 2026; until 31 December 2026 to confirm/update pay systems; monthly data submissions to social security (Sodra) and the right to information only from 1 January 2027. No size exemption |
| Luxembourg | No public draft | N/A | Draft bill signalled as forthcoming |
| Malta | Partial in force | Narrower scope | In force from 27 August 2025. Scope narrower than Directive: disclosure delay allowed; right to information limited to “same work” only |
| Netherlands | Revised draft published | Limited | Revised “clean implementation” draft. Exempts employers under 50 from pay progression; stronger works-council involvement, incl. a consent right over pay evaluation. Implementation no later than 1 January 2027. Government concedes the June 2027 reporting deadline will be missed — first report only in June 2028 |
| Poland | Partial in force | Limited | Recruitment rules in force from 24 December 2025. Broader draft: 30-day response deadline, fixed 31 March notice date |
| Portugal | No public draft | N/A | Working group and capacity-building under way |
| Romania | No public draft | N/A | Draft being prepared; expected but not yet published |
| Slovakia | Act adopted (15.04.2026) | Not expected (minor deviations) | The most advanced Member State. Government approval December 2025; submitted to parliament January 2026; adopted 15 April 2026. Clean transposition. Earlier reporting deadline |
| Slovenia | No public draft | N/A | Working group preparing legislation |
| Spain | No public draft | N/A | Existing pay-register and pay-audit obligations under national law, but no transposition draft |
| Sweden | Draft withdrawn | Was gold-plating | Draft referral 15 January 2026, reversed on 26 March 2026. Government opposes the Directive; seeks renegotiation. No bill before the Riksdag |
See also our dedicated article on Slovakia as the first Member State to transpose the Directive.
Gold-plating — six main types
Gold-plating arises where a Member State imposes obligations on employers that go beyond the Directive’s minimum requirements. A review of the 27 Member States identifies six main types.
1. Scope of application — lowered employer thresholds
The Directive sets a general reporting threshold of 100 employees. France lowers this to 50 employees, materially expanding the number of employers subject to gender pay gap reporting obligations. Denmark achieves a similar effect by routing employers in the 50–99 employee band through its existing statistics-based model. The practical consequence is that mid-sized businesses in those jurisdictions fall within scope years earlier than expected.
2. Pre-employment transparency obligations
Ireland requires pay ranges to be published in job advertisements rather than merely disclosed before the interview, as the Directive would require. Ireland also maintains a website publication obligation that goes beyond the Directive’s framework. Similarly, Italy’s first draft legislative decree requires detailed pay-structure information directly in job advertisements.
3. Universal employer obligations — Lithuania
Lithuania presents the broadest gold-plating across the EU. Its draft would impose mandatory remuneration policies on ALL employers regardless of headcount, introduce monthly pay and working-time reporting through state social security channels, and remove all size-based exemptions for formal gender-neutral pay structures. This materially exceeds every benchmark in the Directive.
4. Procedural deadlines — Poland
Poland illustrates “near-literal transposition plus tougher procedural deadlines”: its broader draft includes a 30-day deadline for right-to-information responses (shorter than the Directive), a fixed 31 March annual notice date, and very tight explanation timelines when trade unions or equality bodies request information.
5. Works-council rights — Netherlands
The Netherlands grants works councils consent rights in areas where the Directive would only require lighter consultation, including a consent right over the pay-evaluation process. This addition exceeds the Directive’s minimum requirements.
6. Automatic justification and an empowered enforcement body — Bulgaria
The Bulgarian draft, although framed as a minimum implementation, introduces several onerous elements. First, employers with fewer than 50 staff are not exempted from pay-progression transparency obligations — unlike the approach in Greece and the Netherlands. Second, where a pay gap of 5% or more is identified, the employer must proactively submit a written justification to the enforcement body, rather than merely keep it available on request. Third, the draft prefers fixed deadlines over the Directive’s more flexible “reasonable period”. Fourth, the role of the Commission for Protection against Discrimination is significantly expanded — from a reactive complaints body into one with proactive monitoring and oversight functions.
Special case: Sweden
Sweden stands apart from all other Member States. After the government published a legislative referral on 15 January 2026 proposing amendments to the Discrimination Act with a proposed entry into force of 1 July 2026, on 26 March 2026 it reversed course. The Swedish government announced that it:
- Considers the Directive too administratively burdensome;
- Wishes to postpone the implementation deadline;
- Seeks renegotiation at EU level;
- Does not currently intend to submit a transposition bill to the Riksdag.
This is a remarkable reversal: the early drafts published in 2025 were themselves examples of gold-plating, since they would have retained the existing national obligation to conduct pay surveys for all employers alongside the new Directive-based reporting layer.
Implications for multinationals: if you have a Swedish subsidiary, the existing national rules continue to apply (including pay-audit obligations), but the new Directive requirements will not be transposed nationally for the foreseeable future. At group level, however, you should still build for compliance with the directly effective minimum standards of the Directive.
Implications for Bulgaria — employers ahead of 7 June 2026
Status: a published draft, targeting the 7 June 2026 deadline
As of 1 June 2026 Bulgaria is no longer among the Member States without a draft. A transposition draft has been published, targeting the 7 June 2026 deadline. This is a material change from the preceding weeks, when the country sat among the 13 Member States without a published text. During EU negotiations the Ministry of Labour and Social Policy opposed extending the scope to small and medium-sized enterprises, yet the published draft in fact does not exempt smaller employers from part of the transparency obligations.
What the Bulgarian draft provides
The draft is presented as a minimum implementation of the Directive, but in several respects it is more onerous than that minimum. The reporting thresholds and the phased timetable broadly follow the Directive, but a number of notable features have been added:
- No relief for smaller employers — employers with fewer than 50 staff are not exempted from pay-progression transparency obligations;
- Proactive justification at a 5% gap — where a pay gap of 5% or more is identified, the employer must itself submit a written justification to the enforcement body, rather than merely keep it available;
- Fixed deadlines — the draft prefers precise time limits over the Directive’s more flexible “reasonable period”;
- An empowered Commission for Protection against Discrimination — from a reactive complaints body into one with proactive monitoring and oversight functions.
Important: the draft is subject to public consultation and parliamentary scrutiny, so some provisions may change before adoption. Even if there is a formal delay beyond 7 June 2026, the directly effective provisions of the Directive may be invoked by employees before national courts, and the European Commission may commence infringement proceedings under Art. 258 TFEU. Preparation should therefore begin regardless of the exact adoption date.
What Bulgarian employers should do now
The substantive requirements of the Directive are now clear, and the national draft confirms the direction of travel. Employers should begin preparation immediately:
- Hiring transparency — disclosure of starting salary or its range in the advert or before the interview;
- Ban on questions regarding the candidate’s prior pay;
- Gender-neutral language in adverts and job descriptions;
- Right to information for employees — average pay disaggregated by sex within the relevant job category;
- Ban on confidentiality clauses on pay where the employee is exercising the right to equal pay;
- Reporting preparation for employers with 150+ employees (first report due 7 June 2027);
- Joint pay assessment where a 5%+ pay gap is identified and not justified or remedied within 6 months.
Strategy for multinational groups operating across several Member States
The uneven European landscape creates a serious challenge for employers operating across several jurisdictions. The transpositions diverge across a number of key parameters:
Divergence across key parameters
| Parameter | Directive | Specific deviations |
|---|---|---|
| Reporting threshold | 100 employees | France: 50; Denmark: 50–99 via statistics model; Lithuania: all employers |
| Pay range disclosure on hiring | Before interview | Ireland and Italy: mandatory in the job advertisement |
| Information request response window | No fixed period | Poland: 30 days; Slovakia: 2 months; Italy: 30 days |
| Joint pay assessment timeline | No fixed period | Slovakia: 2 months from when the obligation arises |
| Annual reporting filing date | No fixed date | Slovakia: 15 April; Czech Republic (proposed): 30 April; Latvia (proposed): 1 June; Poland: 31 March |
| First reporting period | Full calendar year | Slovakia: 1 August – 31 December 2026 (abbreviated) |
| Sanctions | “Effective, proportionate, dissuasive” | Slovakia: €4,000–8,000 + up to €100,000 by Labour Inspectorate; France: up to 1% of payroll |
Recommended approach
- Group mapping — produce an inventory of subsidiaries by country with the current transposition status;
- Highest-bar analysis — in areas with at least one “heavy” jurisdiction (Lithuania, France, Ireland), centralise policies on the strictest standard;
- Phased implementation — start with hiring transparency (universal across all Member States); proceed to job classification; finish with reporting;
- Centralised platform — managing diverging deadlines, formats and requirements across hundreds of employees in more than one market requires dedicated software. app.equalpay.bg was built for this purpose;
- Track infringement proceedings — missed 7 June 2026 deadlines across multiple Member States will accelerate legislative activity in the second half of 2026.
EqualPay.bg — Innovires Legal’s ready-to-use platform for compliance across all 27 Member States
Innovires Legal has developed a dedicated solution covering both the Bulgarian context and the cross-border nuances of the Directive. The platform consists of two layers:
EqualPay.bg — information and expert layer
www.equalpay.bg is a dedicated resource maintained with up-to-date content on:
- Transposition status across all 27 EU Member States, refreshed with every new development;
- Comparisons across the key parameters (threshold, deadlines, sanctions, gold-plating);
- Ready-to-use policy templates for equal pay, adapted to the Bulgarian and to the international context;
- Expert briefings from Innovires Legal lawyers on every new development (act, draft, CJEU ruling);
- Training materials for HR teams and line managers.
app.equalpay.bg — operational compliance platform
app.equalpay.bg is the software handling the operational side of the Directive, including for multinational groups:
- Pay audit — import current data, compare by sex and job category, identify unjustified gaps above 5%;
- Job classification — complexity, strenuousness, responsibility and working conditions, with soft-skills support;
- Multi-jurisdiction templates — ready configurations for the requirements of Slovakia, France, Ireland, Lithuania and others for groups operating across several countries;
- Information request management with automatic deadline tracking across countries (30 days in Poland, 2 months in Slovakia etc.);
- Report preparation aligned with the expected Bulgarian format and the format of other Member States;
- Joint pay assessment — a guided module that runs the process when a 5%+ gap is identified;
- Multilingual interface — Bulgarian, English and others, suitable for multinationals operating in Bulgaria.
See also our companion articles: Directive 2023/970 — overview, job advert transparency, pay gap reporting, sanctions for breaches.
Outlook — what to expect ahead of 7 June 2026 and beyond
The pace of legislative activity is set to remain high around the deadline. Based on current signals:
- Germany is expected to publish a draft around 20 June 2026, after the Federal Cabinet’s review slipped from 27 May to June; Greece is about to publish its already-developed draft; Spain, Romania and Belgium (private sector) are also expected to bring forward texts;
- Several Member States will adopt texts on or around the deadline, but without full legislative enactment, likely relying on interim measures or secondary legislation;
- Gold-plating will be a feature in at least 7–8 Member States; the practice is most concentrated in pre-employment transparency and employer headcount thresholds;
- Several Member States (including Greece and likely Germany) will face infringement proceedings for incomplete or delayed transposition; Bulgaria has published a draft, but final adoption by 7 June remains uncertain;
- The interaction between the Pay Transparency Directive and existing national pay-audit and gender pay gap reporting frameworks (Finland, Ireland, Netherlands, Sweden) will require careful legal analysis for multinationals;
- CJEU rulings are expected in mid-2027 on the first preliminary references already received from national courts.
Get ready with Innovires Legal + EqualPay.bg
Whether you operate only in Bulgaria or you run a group with dozens of EU subsidiaries, implementing the Directive is a question of when, not if. Innovires Legal offers a combined product — legal expertise for the Bulgarian context and for compliance with the other 26 Member States, plus the ready-to-use platform app.equalpay.bg for the operational delivery. For employers with 150+ employees we recommend a pay audit as early as May 2026; for smaller employers — hiring-transparency and on-request information policies. Reach out for a free 30-minute consultation — we will assess your readiness and produce a personalised compliance roadmap.