2025 Mid-Year Check-In: Where Europe Stands on the EU Pay Transparency Directive

The EU Pay Transparency Directive (EUPTD) is rapidly moving from policy to practice. By mid-2025, multiple member states are enacting legislation, and business leaders must adapt now to avoid legal and reputational risk.

This update outlines what has changed, what is coming, and how strategic employers should respond.

1. The Directive Remains Intact – No Rollbacks or Delays

The European Commission’s Omnibus IV review left EUPTD untouched. No softening. No deferral. Transparency is non-negotiable.

The Clock Is Ticking: With the Directive locked in, companies need to transition from planning to execution—2025 is the final runway before mandatory compliance begins

2. Country-Level Legislation is Accelerating

Sweden

• Draft law (SOU 2024:40) released in May 2024, enforcing transparency rules including pay ranges in job ads and banning salary history inquiries.
• Final legislation expected Q3 2025, in force by June 2026.

Netherlands

• Draft legislation (March 2025) transposes the directive and lowers the reporting threshold to 100 employees.
• The burden of proof in discrimination cases will shift to the employer.

Lithuania

• The new draft law (May 2025) includes the right to pay info requests and a ban on salary history questions.
• Emphasis on gender-neutral job classification and fairness in internal structures.

Ireland

• Equality Bill (January 2025) aligns with EUPTD by expanding the definition of “equal work.”
• Includes mandates for salary ranges in job ads and improved transparency during recruitment.

Poland

• Labour Code amendment (May 2025) requires employers to respond to pay information requests within 14 days (stricter than the directive’s 2-month standard).
• Prohibits asking about past salaries and mandates more accessible pay data disclosure.

Adaptability Is Essential: Legal obligations will vary by country. Enterprises require flexible compliance systems that can adapt to local requirements without compromising global coherence.

3. Deadlines Are Closer Than They Appear

• 7 June 2026: EUPTD must be transposed into national law.
• 2026 calendar year: First year of mandatory pay data collection.
• 7 June 2027: First public reports due for companies with 250+ employees.

What it means: Mid-2025 is the practical start line. Delayed action now will lead to rushed reporting, risk exposure, and reputational damage. The risks are serious:

• Regulatory penalties for non-compliance
• Inaccurate or incomplete data exposure during audits
• Brand and trust erosion if transparency lags behind peers
• Lost investor confidence in governance and risk management
• Employee attrition driven by perceived pay inequity

Non-compliance isn’t just a legal issue, it’s a strategic one. Companies that wait will likely face higher costs, lower control, and greater reputational vulnerability than those who act now.

4. Proactive Compliance Becomes Competitive Advantage

The companies that move early won’t just avoid risk—they’ll get ahead. Proactive organizations have more time to improve data quality, align stakeholders, and shape their narrative before public reporting begins.

This isn’t just about checking a legal box; it’s about earning employee trust, investor confidence, and reputational capital. The earlier you start, the more control you have.

With platforms like uFlexReward, early adopters can leverage real-time, structured reward data to move beyond compliance, proactively demonstrating fairness, boosting internal trust, and positioning themselves as transparency leaders.

What’s at stake: Early movers gain flexibility, reduce pressure, and turn compliance into a lever for strategic positioning.

5. What Does This Mean For The Employee

Transparent pay practices aren't just a compliance obligation; they're a foundation for trust, fairness, and engagement.

For companies operating in the EU, meeting the EUPTD standard signals to employees that leadership values equity and is willing to be accountable for it. That builds credibility, especially in a talent market where employees expect more than just compensation; they expect clarity.

The payoff? Reduced turnover, stronger employer branding, and greater ability to attract top talent, especially among younger, transparency-driven workers.

6. Employer Requirements Are Strategic, Not Administrative

Every covered company must:

• Publish pay ranges in job ads
• Prohibit salary history questions
• Grant employee access to peer-level pay comparisons
• Report gender pay gaps and trigger corrective actions for gaps >5%

Bottom line: Meeting these requirements will drive long-term value through stronger data, better hiring, and increased employee trust.

7. The Strategic Stakes Are Rising

EUPTD is not just a policy change — it’s a cultural shift. Companies that lead with transparency will:

• Build stronger employee trust
• Enhance brand equity and retention
• Avoid costly, last-minute compliance efforts

Key takeaway: Success hinges on a tight alignment between the CHRO and CFO to ensure data accuracy, reporting integrity, and fair pay practices.

Where uFlexReward Can Help

For organizations looking to simplify and scale their compliance efforts across multiple jurisdictions, uFlexReward offers:

• Real-time consolidation of global pay and reward data
• Automated reporting aligned with EUPTD and national variations
• Scenario modelling to assess costs and correct disparities
• Role-based access for employee-level transparency and board-level insights

We're supporting multinational enterprises through every phase — from strategy to reporting.

To explore how we can support your next step, reach out at info@uflexreward.com