Transposition of the EU Pay Transparency Directive Across the 27 Member States — Status as of 30 April 2026 and Implications for Bulgarian Employers

The overall picture as of 30 April 2026

Six weeks before the deadline the EU position is strikingly uneven. Most Member States are still at preparatory consultation stage or have no public draft. Drawing on the L&E Global review as of 20 April 2026 and updated to 30 April 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 and the Netherlands. Sweden presents a unique situation: 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that it opposes the Directive and seeks renegotiation at EU level — making it the only Member State to have publicly withdrawn from the transposition process.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 30 April 2026.

See also our dedicated article on Slovakia as the first Member State to transpose the Directive.

Gold-plating — five 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 five 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, and extends the personal scope to include temporary agency workers. Both additions exceed the Directive’s minimum requirements.

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 Bulgaria — employers ahead of 7 June 2026

Status: 13th Member State without a published draft

As of 30 April 2026 Bulgaria sits among the 13 Member States without a published transposition draft. Per the Ministry of Labour and Social Policy’s position during EU negotiations, Bulgaria opposed extending the Directive’s scope to small and medium-sized enterprises. Preparatory work is reportedly under way, but no text has been published for public consultation.

What follows if Bulgaria misses the 7 June 2026 deadline

1. Infringement proceedings by the European Commission under Art. 258 TFEU, leading to potential financial sanctions following a CJEU ruling;
2. Direct effect of those provisions of the Directive that are sufficiently clear and unconditional — employees may invoke them before national courts after 7 June 2026;
3. A temporary legal vacuum in which multinational companies operating in Bulgaria will rely on group-level policies, without local statutory certainty;
4. Uncertainty as to the reporting threshold, the report format, the response deadline for information requests and the sanctions framework.

What Bulgarian employers should do now

Notwithstanding the absence of a national law, the substantive requirements of the Directive are settled and 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

Recommended approach

1. Group mapping — produce an inventory of subsidiaries by country with the current transposition status;
2. Highest-bar analysis — in areas with at least one “heavy” jurisdiction (Lithuania, France, Ireland), centralise policies on the strictest standard;
3. Phased implementation — start with hiring transparency (universal across all Member States); proceed to job classification; finish with reporting;
4. 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;
5. 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:

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 accelerate sharply in the next six weeks. Based on current signals:

• Germany, Spain, Romania and Belgium (private sector) are expected to publish draft texts in the run-up to the deadline;
• 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 5–7 Member States; the practice is most concentrated in pre-employment transparency and employer headcount thresholds;
• At least ten Member States (including Bulgaria) will face infringement proceedings for failure to transpose on time;
• 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.

Frequently asked questions