EU Pay Transparency Directive: where Poland, Lithuania, Latvia and Estonia stand

The EU Pay Transparency Directive, Directive (EU) 2023/970, had a transposition deadline of 7 June 2026 for all 27 member states. That deadline has passed. Most member states missed it, and the four countries (Poland, Lithuania, Latvia, and Estonia) Go-EOR operates in are each at a different stage. If you hire in Poland, Lithuania, Latvia, or Estonia, the practical question is not whether the Directive applies eventually. It is what is already enforceable in your specific market today.

Where each market stands, as of September 2026

These statuses will keep moving. The European Commission confirmed on 18 December 2025 that no EU-level extension was granted, and it has signalled it will pursue infringement proceedings against member states that remain non-compliant. If you operate in any of these four markets, checking current status against the country’s own authority before relying on this table is worth doing since national timelines shift month to month.

What the Directive actually requires

Regardless of exactly how far each country has transposed it, the core obligations under Directive (EU) 2023/970 are consistent:

• Job postings and pre-interview communication must include a salary or salary range, based on objective, gender-neutral criteria
• Employers cannot ask candidates about their pay history
• Pay-secrecy clauses that stop employees discussing their own pay are unenforceable
• Employees gain a right to request information on their own pay and the average pay of colleagues doing the same work or work of equal value, broken down by gender
• Employers with 100 or more workers face gender pay gap reporting obligations, phased by size: 250-plus employees report annually from 7 June 2027 using 2026 data, 150 to 249 employees report every three years from 7 June 2027, and 100 to 149 employees join the regime from 2031
• Where an unexplained gender pay gap of 5% or more in a job category is not resolved within six months, employers must carry out a joint pay assessment with worker representatives

Why partial transposition still matters

A country having only partially transposed the Directive does not mean the rest of it is safely ignored. Poland and Estonia have already brought pre-employment obligations into force, including pay ranges in job postings and a ban on pay-history questions, ahead of the rest of the framework. If you are actively hiring in either market right now, those specific requirements already apply to your job postings, regardless of when the full reporting regime lands.

Latvia has no dedicated pay transparency regime in force yet, but the draft legislation is advanced enough that building compliant pay structures now, rather than scrambling once the law passes, is the lower-risk approach. Employers with 150 or more staff across the EU should also start collecting gender-disaggregated pay data now, since the first reporting deadline of 7 June 2027 for larger employers is fixed regardless of how national transposition unfolds.

What to do now, market by market

• Poland: update job postings to include a pay range and stop asking about salary history, since these provisions are already in force
• Lithuania: the full regime applies. Review job postings, pay-secrecy clauses, and your process for handling an employee’s request for pay information
• Estonia: update job postings and remove pay-secrecy clauses now, and expect the reporting and joint assessment obligations to follow once the government’s push for postponement is resolved
• Latvia: no legal requirement is in force yet, but pay data hygiene now avoids a scramble once the draft becomes law
• Across all four: if you have 150 or more employees in the EU, begin collecting gender-disaggregated pay data now, since the June 2027 reporting deadline for larger employers does not depend on national transposition timing

Where Go-EOR can help

Employment contracts, payroll, and benefits administration for your team in Poland, Lithuania, Latvia, or Estonia already run through Go-EOR’s local entities in each of those countries. As pay transparency obligations phase in, we track what applies in each market and flag what it means for contracts and payroll practice, so this does not become one more compliance thread your internal team has to monitor market by market.

Has the EU Pay Transparency Directive been delayed?

No. The European Commission confirmed on 18 December 2025 that the 7 June 2026 transposition deadline would not be extended. Individual member states missing that deadline is a separate issue from the Directive itself, which is already EU law.

If my country hasn’t transposed the Directive yet, do I need to do anything?

In Poland and Estonia specifically, pre-employment provisions, meaning pay ranges in job postings and a ban on pay-history questions, are already in force. Even in Latvia, where no law is in force yet, employers with 150 or more EU staff should start collecting pay data now ahead of the fixed June 2027 reporting deadline.

What counts as a gender pay gap that triggers a joint pay assessment?

An unexplained gap of 5% or more within a job category that is not remedied within six months triggers the requirement for a joint pay assessment with worker representatives.

Does this apply to small companies?

Gender pay gap reporting obligations phase in starting at 100 employees, with the fullest requirements applying to employers with 250 or more staff first. The pre-employment provisions on pay ranges and pay-history questions generally apply regardless of company size once a country has transposed them.

Hiring in Poland, Lithuania, Latvia, or Estonia and unsure what your job postings and contracts need to reflect right now? Get in touch with Go-EOR