Slovakia — the First EU Member State to Transpose Directive 2023/970 on Pay Transparency: What This Means for Bulgaria (June 2026)

What happened in Slovakia — the first national transposition

On 15 April 2026 the National Council of the Slovak Republic adopted the Equal Pay Act — the national transposition of Directive (EU) 2023/970 on Pay Transparency. The Act enters into force on 7 June 2026 — on the exact deadline set by the Directive. Slovakia thus becomes the only Member State to cross the line on time.

The Slovak government committed to transpose the Directive closely and faithfully, and the Act largely delivers. There are, however, several notable deviations and elements of gold-plating that multinational employers need to understand.

Slovakia — key dates

Specifics of the Slovak transposition — what employers need to know

1. Same-sex equal pay claims (gold-plating)

One of the most significant deviations: the Slovak Act recognises an equal pay claim also between employees of the same sex performing equal work or work of equal value. Traditional equal pay frameworks compare only male and female employees — but in a tech firm where 90% of engineers are male and individual salaries vary widely due to negotiation, market timing or commission structures, those gaps could not be challenged under the classical model. Slovakia’s approach changes that — every employee may compare with every colleague, regardless of sex, and the employer must justify the gap. Slovakia has effectively legislated not just for equal pay, but for fair pay.

2. Job evaluation criteria

The Directive refers to “skills” and “effort”. The Slovak Act replaces these with “complexity” and “strenuousness”, and adds an explicit requirement to consider soft skills — in particular social and communication skills. Modest gold-plating.

3. Response windows

The Directive requires the employer to respond “within a reasonable time”. Slovakia specifies:

• 2 months — for an initial request for individual pay information;
• 30 days — for follow-up questions on individual pay;
• 30 days — for questions on the pay gap report;
• 2 months — for completing a joint pay assessment (JPA).

4. Penalties — small at face value, larger in substance

Fines for breaches of reporting obligations range from €4,000 to €8,000 — on its face insufficient for “effective, proportionate and dissuasive” penalties. However, the explanatory materials clarify that the Equal Pay Act amends the Slovak Labour Inspection Act, granting the Labour Inspectorate the power to impose fines of up to €100,000.

5. First reporting period — abbreviated

Slovakia provides that the first reports for employers with 150+ employees (due 7 June 2027) cover only 1 August 2026 – 31 December 2026, not a full calendar year. This is likely to be reviewed by the European Commission as potential under-implementation.

Reporting timelines in Slovakia — and an uneven European landscape

Diverging deadlines across jurisdictions

Multinational employers already face a fragmented European landscape:

• Slovakia — 15 April
• Czech Republic — proposed 30 April
• Latvia — proposed 1 June
• Estonia — on 16 April 2026 announced it would prefer to pay a fine rather than transpose, but later partially walked back, confirming it would retain the ban on prior-pay questions and the duty to disclose salary ranges;
• Bulgaria — as of 27 April 2026 no draft bill.

Managing these diverging deadlines and obligations across pan-European groups requires a centralised platform — precisely the role of our SaaS, app.equalpay.bg.

What lies ahead for Bulgaria — the run-up to 7 June 2026

Transposition status

As of 27 April 2026 Bulgaria has not published a draft bill transposing Directive (EU) 2023/970. The Ministry of Labour and Social Policy opposed the broadening of the Directive’s scope to small and medium-sized enterprises during EU negotiations. Even so, when the deadline passes (7 June 2026) without a national transposition, we expect:

• Infringement proceedings by the European Commission, with potential financial penalties;
• Direct effect of Directive provisions with vertical direct effect — employees may invoke them before national courts;
• A temporary legal vacuum during which multinationals operating in Bulgaria will rely on group-level policy, without local statutory certainty.

Expected obligations on Bulgarian employers

Notwithstanding the delay, the substantive requirements of the Directive are settled and employers should start preparing now:

1. Hiring transparency — disclosure of starting salary or range in the advert or before the interview;
2. Ban on questions about prior pay of the candidate;
3. Gender-neutral language in adverts and job descriptions;
4. Right to information for employees — average pay disaggregated by sex within their job category;
5. Ban on confidentiality clauses on pay where the employee is exercising the right to equal pay;
6. Pay reporting:
   • Employers with 150+ employees — from 2027;
   • Employers with 100–149 — from 2031;
   • Employers with under 100 — voluntary.
7. Joint pay assessment where a 5%+ gap exists and is not justified or remedied within 6 months.

Possible “Bulgarian” deviations

By analogy with the Slovak experience, we may expect:

• A Directive minimum (no gold-plating) — consistent with the Ministry of Labour’s previous stance;
• A possibly abbreviated first reporting period (as in Slovakia);
• Sanctions likely to be embedded in the Labour Code and the Labour Inspection Act;
• Possible expansion of the powers of the General Labour Inspectorate (GLI);
• Additional burden for employers in updating CLAs and internal regulations.

EqualPay.bg — Innovires’ ready-to-use platform for Directive compliance

Innovires has invested in a dedicated platform to help Bulgarian employers meet the Directive’s requirements without months of in-house build. The platform has two layers:

For employers requiring full legal support — from diagnosis of current state through corrective actions, drafting policies and employee communications — the Innovires Legal team combines the platform with legal expertise. See our articles on Directive 2023/970, job advert transparency and pay gap reporting.

What to do now — an action plan for 7 June 2026

For employers with 150+ (priority 1)

1. Now — pay audit on app.equalpay.bg or with an external expert;
2. May 2026 — introduce job classification under new criteria;
3. June 2026 — revise job adverts — include the starting salary range;
4. July 2026 — internal equal-pay policy; HR and manager training;
5. August–December 2026 — collect data for the first report;
6. Q1 2027 — prepare the first report with platform support;
7. By 7 June 2027 — submit the first report to the GLI.

For employers with 100–149

The first report is for 2031, but the hiring transparency and on-request information requirements apply immediately. Recommended: start preparation in 2026.

For employers under 100

Reporting is voluntary, but hiring transparency and the prior-pay question ban are mandatory. Apply from the day the Bulgarian law enters into force.

Slovakia vs Bulgaria: what is (likely) to differ

Frequently asked questions