Pay Transparency in Progress

Annex B. Key actors involved in the definition and implementation of changes related to the EU Pay Transparency Directive

Table A B.1. Key actors involved in the definition and implementation of changes related to the EU Pay Transparency Directive

Country	Drafting the law	Negotiations	Consultation, advice	Implementation	Tools, methodologies	Other	Comments
Austria	NG	NG; SP-N		NG	NG; SP-N		NG is responsible for the labour law in the private sector at federal level and for public service law at federal level
Belgium	NG; SG	SP-N	SP-N	NG; SP-N	NG; SP-S	SP-S	NG: Framework law for everything not covered by collective bargaining agreements between social partners within the CNT; development of tools to assist sectors SG: Regulations applicable to the public sector in regional governments SP-N: Transposition of the directive via collective bargaining agreements SP-S: Execution/implementation of the obligations of the directive via collective bargaining agreements
Czechia	NG		SP-N; SP-S; CU; Other		NG
Denmark	NG	NG	NG; SP-N; SP-S	NG; SP-N; SP-S; CU	NG; SP-N; SP-S; CU
Estonia	NG		NG, SG, SP-N, SP-S, CU				The Ministry of Economics and Communication is responsible for transposition of the directive.
Finland	NG	NG; SP-S	CU; Other	NG	NG		Other actors involved in consultation include National Statistics and Ombudsman for Gender Equality.
France	NG		NG; SP-N	NG	NG		NG drafts legislative and regulatory texts; organises consultations with social partners (also regarding the transposition of the Directive); provides tools and support for stakeholders involved (employers, trade unions, employer organisations) A sample of volunteer companies will be invited to test the declaration website that is being developed, prior to its public launch
Germany							As the details of the implementation of the EU Pay Transparency Directive are still being discussed in Germany, it is not possible to provide information on the key actors at this point.
Greece					NG		NG: Implementation of FAIR PAY Project, with other stakeholders – NGO Women on Top, and NGO Association of Women Entrepreneurs of Greece (SEGE)
Hungary	NG	NG					NG has started to set up a working group and to assess the legislative tasks to begin the transposition process
Ireland
Italy	NG	NG	NG, SP-N, SP-S, Other	NG, SP-N, SP-S, Other	NG, SP-N, SP-S, Other		NG: Minister of labour has to prepare the first draft of the law for the transposition of the European directive. To this aim the consultation of social partners is currently ongoing, on the one hand, while the minister is actually co‑operating with a research institute (INAPP) since 2022. The draft will be shared with other Ministers, before its approval. SP: Social partners, at national and sectoral level, have been informed of the contents of the directive since 2023 and have been actively involved in the transposition, through a consultation process that is still ongoing. Other: Research and academic institutes and equalities bodies
Latvia	NG	NG, SP-N	NG	NG	NG		Ministry of Welfare and State Chancellery are main actors involved in the transposition process of the Directive.
Lithuania	NG	NG SP-N	NG; SP-N	NG; SP-N		SG; SP-S CU; Other	NG: prepared proposals for amendments to the laws, presented them to social partners, is currently co‑ordinating the final text of the laws with social partners SP-N: evaluates the proposed amendments to the laws, makes suggestions for their improvement SP-S: some partners participate in social dialogue Other: When transposing the directive, the accountants’ association is consulted on data collection. Data collection solutions are sought with other public sector institutions.
Luxembourg	NG	SP-N	SP-N; SP-S; CU	NG	NG
Netherlands	NG	SP-N		NG; SG; SP-N; SP-S; CU	NG; SP-N; SP-S	.	NG should implement the Directive. In facilitating employers, the Ministry of Social Affairs and Employment will design tools/guidelines, for instance for pay structures. Also, the NG, as employer, will implement the Directive in its organisation. Regional governments are employer themselves, so will implement the Directive Social partners are involved in designing the draft law of the implementation of the Directive. Besides that, they are involved in implementing, to provide tools for SME. Social partners also have specific tasks, for instance for the right for requests of employees. On sectoral level, social partners are involved in designing tools for the implementation of the Directive. They sometimes design these structures themselves or transpose them in collective agreements. Company level unions, most specifically workers councils, are involved in implementing the Directive. They have specific roles with some transparency obligations, e.g. in the process of checking pay reports and solving pay differences.
Poland	NG		SG; SP-N; SP-S; CU	NG	NG		NG will draft a bill to implement the Directive, which will be sent to the parliament. The draft law will be consulted within the framework of the Joint Commission of Government and Local Self-Government. The role is not the result of the transposition of the Directive. Entities can submit comments as part of the consultation. These roles are not the result of the transposition of the Directive.
Portugal	NG
Slovak Republic	NG; SG; SP-N; SP-S; CU; Other	NG; SG; SP-N; SP-S; CU; Other	NG; SG; SP-N; SP-S; CU; Other	NG; SG; SP-N; SP-S; CU; Other	NG; SP-N; SP-S; CU; Other		Other actors: Public Slovak National Centre of Human Rights (Equality Body); National Labour Inspectorate.
Slovenia							No response
Spain	NG	NG; SP-N	NG; SP-N	NG	NG; SP-N
Sweden	NG	SP-N	NG; SG; SP-N; SP-S; CU; Other				The government propose law to the parliament. The report on the transposition of the Directive has been sent for referral.

Note: NG stands for National Government. SG stands for Sub-national government. SP-N stands for Social partners at a national level. SP-S stands for social partners at a sectoral level. CU stands for company unions.

France answered for the private sector only.

Source: 2025 OECD Pay Transparency Questionnaire.