As the 7 June 2026 transposition deadline approaches, countries across the EU are at various stages of implementation, leading to a dynamic and sometimes challenging landscape for businesses operating internationally. In this blog, which is part of our series ‘pay transparency revolution’, we provide a snapshot of recent developments in Belgium, France, Italy, Ireland, and the Netherlands, with a special focus on Ireland, leading the way to subsequent blogs that will delve deeper into the specifics of the other above-mentioned countries.
Recent months have seen a flurry of activity as member states are grappling with the EU Pay Transparency Directive's (Directive) requirements. In Italy, a draft law aiming to transpose the Directive was approved by the Council of Ministers on 5 February 2026. The draft is now under the examination of the parliamentary committees, before returning once again to the Council of Ministers for final approval, therefore it might still be subject to changes. The draft closely follows the Directive, albeit with a few noteworthy national specificities. Belgium also saw proactive steps, with a resolution proposed by the Chamber of Representatives of 26 January 2026, requesting the federal government to adhere to the results to be achieved when implementing this Directive and in that context (i) avoid “gold-plating” and in line with the government agreement of January 2025, not to create new legislation that goes beyond the strict requirements of the Directive, (ii) limit legislative changes (for the private sector, implementation should be confined to minor textual amendments to the existing legislation), address the administrative burden on companies .
Meanwhile, the Netherlands, which initially published a draft law in March 2025 that largely stayed loyal to the Directive’s provisions (read our blog post on the initial draft), has presented an amended version in January 2026. Key aspects of the revised draft include: an adjusted definition of ‘employer’ now stating that the employer is the party with whom the employee has entered into an employment contract or public law appointment; a shift from the term of ‘wage structures’ (loonstructuren) to ‘job evaluation and classification systems’ (systemen voor functiewaardering en -indeling); the removal of the works council’s obligation to confirm reporting accuracy, preventing them from having formal responsibility for employer’s reporting obligations; a clarification that personal data may only be used for equal pay application, emphasizing privacy; and the conditional allowance for consolidated reporting within concerns. In France, a draft law proposal from the Ministry of Labour is still expected. As part of its last consultation meetings with social representatives in January 2026, several measures were presented and reported by the press, in particular:
- A new version of the gender equality index, which should apply from 2027.
- An obligation to indicate an initial salary range in job offers and to present the applicable industry-wide collective bargaining agreement provisions, as well as a prohibition on asking candidates about their previous salary.
- The creation of a right to salary information, no later than June 2027. Upon request, employers will be required to provide the information within a reasonable period (maximum two months).
- Two types of penalties: (i) for obligations related to the equality index, a maximum of 1% of the payroll, and (ii) for other provisions of the directive, a fine of EUR 450 per breach.
Turning our attention to Ireland, it is becoming increasingly clear that it is unlikely to meet the 7 June deadline for full transposition. In January, it was reported by the Industrial Relations News that employers’ representative body, IBEC, has formally called for a one-year postponement, due to a “significant concern” regarding the ability of employers to comply with the Directive by this summer.
In response, the Department of Children, Disability and Equality (DCDE), which is tasked with overseeing the transposition process, has confirmed that it “will work with employers, employees and their representatives in the implementation of the Directive, which will be on a phased basis”. In particular, the DCDE stated that employers “will not be penalised for not having all elements of Directive completed in June 2026”, thus providing some reassurance to businesses grappling with the upcoming changes.
IBEC has acknowledged the difficulties faced by the DCDE, particularly due to the delay in the finalisation of Commission guidance, and in particular the European Institute for Gender Equality (EIGE) toolkit, which has had a “knock-on effect” on the publication and rollout of a national toolkit for job categorisation. Once this national toolkit is published, the DCDE expects to commence workshops between April and July 2026, designed to assist employers in carrying out the job evaluation exercise required by the Directive. According to the DCDE, Ireland’s existing Gender Pay Gap Information Act 2021 has already brought into effect “a large portion of the Directive, particularly in relation to Article 9 on gender pay gap reporting”.
Regarding the legislative progress, the General Scheme of the Equality (Miscellaneous Provisions) Bill, which contains provisions to transpose Article 5 of the Directive concerning the provision of information on salary to potential employees, was referred to pre-legislative scrutiny in June 2025. This scrutiny was completed in October 2025, and officials are currently considering the recommendations outlined in the pre-legislative scrutiny report. The DCDE further indicated that it is developing a General Scheme to transpose the remaining elements of the Directive into Irish law and “is continuing to work on additional measures to assist with the transposition of the Directive as soon as possible”.
According to IBEC, a key concern is that employers, upon receipt of the national toolkit and legislation may then have to incur further costs and devote further resources to ensure that their efforts to date are aligned with the national toolkit and legislation. It also stressed the complexity of a categorisation exercise across the entire workforce in a manner compliant with national law.
While it seems safe to say the transposition deadline will not be fully met by Ireland, we do anticipate further progress in the near future, particularly with the publication of draft legislation and the much-awaited job categorisation toolkit.
It remains to be seen whether the proposed “phased approach” of Ireland or that of the Netherlands (i.e., postponing the entry-into-force date to 1 January 2027)) will spill over across the EU. We will continue to monitor the situation closely and provide updates as they emerge.
*This blog post has been co-authored with our Irish colleague Triona Sugrue from A&L Goodbody, which is part of Freshfields’ StrongerTogether network of partner firms around the globe.
