Quick Hits
- On 18 December 2025, the European Commission announced that it expects all EU member states to complete implementation of the EU Pay Transparency Directive by the 7 June 2026 deadline.
- Employers that fail to comply with the obligations of the directive risk regulatory sanctions.
The question in Parliament followed the Netherlands’s announcement that they expect delays in its implementation of the directive until January 2027. However, the EC reaffirmed its position, stating, “the Pay Transparency Directive is instrumental for the full realisation of the right to equal pay for the same work or work of equal value between women and men and remains fully committed to its effective and timely implementation. It expects all Member States to implement the directive by the deadline of June 2026.” The full implications of potential postponement are currently unclear, and the Netherlands has not yet responded to the EC’s announcement.
The progress of the directive across member states continues to take place at varying stages. For employers, this means that the directive is set to be implemented without extension, and any preparations for the directive’s obligations remain reliant on the current timeframe. Employers that fail to prepare now for the June 2026 implementation deadline may find that they are inadequately prepared and risk being noncompliant. Employers are encouraged to stay informed about the implementation process in their respective jurisdictions. Information and updates on the progress of the directive’s implementation across the European Union can be found using Ogletree Deakins’ Member State Implementation Tracker.
For more on the EU’s pay transparency directive, see our previous articles, “EU Pay Transparency Directive: Updates on Implementation Across Member States,” “Preparing for the EU’s Pay Transparency Directive,” “EU Pay Transparency Directive: ‘Equal Pay for Equal Work or Work of Equal Value,” “Implementing the EU Pay Transparency Directive in Malta—New Obligations Effective From 27 August 2025,” “Netherlands Announces Delay in Implementation of the EU Pay Transparency Directive,” “The June 2026 EU Pay Transparency Directive Implementation Deadline Looms,” and “Poland’s Draft Pay Transparency Law to Mandate Job Evaluations Under New Government Tool.”
Further information can also be found by listening to our podcast, “Understanding the EU Pay Transparency Directive: What Employers Need to Know.”
Ogletree Deakins’ London office, Pay Equity Practice Group, and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Cross-Border, Pay Equity, and Workforce Analytics and Compliance blogs as additional information becomes available.
Daniella McGuigan is a partner in the London office of Ogletree Deakins and co-chair of the firm’s Pay Equity Practice Group.
Lorraine Matthews, a practice assistant in the London office of Ogletree Deakins, contributed to this article.
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