With the June 2026 deadline fast approaching, Italy has joined the list of countries in the European Union taking a major step towards transposing 2023’s EU Pay Transparency Directive into its own laws. This compliance alert looks at some of the known specifics of Italy’s approach and provides a quick overview of the progress of other EU member states.
Summary
As reported in The National Law Review, the Italian Government has prepared and issued a first draft of the legislation after a period of consultation with unions and other employer organizations.
At the time of writing, the draft has not yet been published in the Gazzetta Ufficiale, but initial analyses in legal circles indicate that while the text remains close to the original directive, there are a number of additional items unique to Italy’s proposed implementation.
These key differences include:
- Collective bargaining agreements are emphasized as the primary tool to define “work of equal value.” Other member states instead rely on employer-designed job architectures and evaluation frameworks, and while these are permitted in the Italian version of the law, they’re to be considered secondary.
- Using candidate salary history as a basis for offers during recruitment is prohibited. Employers must not request this information from the candidate or obtain it from other sources.
- Initial salaries, component elements of pay, pay periods, and pay methods must be communicated during recruitment.
- Employers with fewer than 50 employees will be exempt from disclosing progression criteria.
- Employers that adopt a unified group wage policy can provide pay gap reporting information by aggregating data at a national level.
Progress Elsewhere in the EU
Considering there are only four months to go until the EU’s deadline, there’s less progress on transposition than you might expect. No member state has produced final legislation covering all elements of the directive and applied it nationally. Partial final legislation has been achieved in:
- Belgium: Employers in the French-speaking majority region of Wallonia, as well as the capital, Brussels, are subject to a fully transposed EU Pay Transparency Directive
- Malta: Is aligned with the pay transparency elements of the directive only
- Poland: Is also currently aligned only with the pay transparency provisions.
Meanwhile, the following states have publicly released draft legislation (links are in local languages):
- Belgium: Released draft legislation in January 2026 covering all of Belgium.
- Cyprus: Released draft legislation in November 2025.
- Finland: Has released draft legislation and recently closed its consultation period. It is targeting May 2026 for final legislation.
- Ireland: Has had a draft bill available since 2025.
- Lithuania: A draft was discussed in a July 22 2025 meeting of the Tripartite Council of the Republic of Lithuania
- The Netherlands: Advanced draft legislation to State Council review in January 2026
- Poland: Poland is working on transposing the remaining components of the legislation and released draft legislation in December 2025.
- Slovakia: A draft law is currently in discussion in the National Council of the Slovak Republic.
- Sweden: Draft legislation was introduced in January 2026 with a proposed implementation date of July 1, 2026.
Who Is Impacted?
As we’ve previously covered in our EU Pay Transparency reporting, these laws will affect organizations with employees working within any of the 27 states of the European Union. The directive will also apply to organizations with employees in Northern Ireland (due to the UK’s post-Brexit obligations).
Additionally, the directive outlines the following thresholds for reporting:
- Annual reporting of the gender pay gap in your organization for companies with 250 or more employees
- Gender pay gap reporting every three years for organizations with between 100 and 250 employees
- No reporting obligation for organizations with fewer than 100 employees
Recommended Actions
Organizations should take the following top-level actions:
- Identify your organizational footprint in Europe by confirming where your employees are located
- Cross-reference this footprint with the current legislative progress of pay transparency law in the relevant EU states
- Conduct a pay transparency gap analysis
- Prepare pay gap data for publication if required (based on your organizational size and footprint)
- Update recruitment, job posting, and communication practices in line with the EU’s base requirements and any extra requirements in local laws
- Review and redesign pay structures as required by the directive’s core obligations
- Build an employee right-to-information process
- Continue to monitor country-level legislative developments
How Affirmity Can Help
- Read our ebook, “Preparing for the EU Pay Transparency Directive: A Guide for Global Businesses” to learn more about the main provisions of the incoming directive
- Contact the Affirmity team to learn how our pay analysis services and software can help you comply as laws are finalized.
Affirmity is on hand to help you deliver pay transparency and address the issues you proactively uncover—contact us today to get started.
About the Author
Kim Hendon oversees account management and sales for Affirmity. She is responsible for building successful, long-term partnerships with clients and generating new business. Having served with the company for more than 25 years, Ms. Hendon has in-depth knowledge and broad experience in all areas of workforce analytics and HR compliance.
Ms. Hendon assists clients with the planning and development of workforce compliance and non-discrimination programs, as well as employee engagement initiatives. She holds a Bachelor of Arts in Speech Communication and a Master’s in Business Administration. Connect with her on LinkedIn.