Directive (EU) 2023/970 · My monitoring list

Transparent pay under control.

Overview · Transposition status · Implementation status · Team tasks

01Legal entities02Countries03My monitoring list04Team tasks05Indicators06Audit timeline
PULSE · 2026-09-23

Recommended next steps

Request a review of your implementation scope. This status is not legal advice.

8 · 67093b14bb7c
Source checked on: 2026-09-23
2026-09-23newly verified existing fact

Regional enactment separated from national implementation

Upper Austria’s completed regional amendment is now recorded. It does not establish nationwide private-employer commencement; final signed-text retrieval was limited.

AT02AT03AT04
2026-09-23verified schedule change

Parliamentary debate moved to Week 50 of 2026

The live official entry now places the debate in 7–13 December 2026, not Week 02 of 2027. The original event ID is retained for workspace continuity; no commencement or reporting date is automatically changed.

NL01NL04NL05
2026-09-23verified procedural change

Tacit-adoption marker corrected to 17 October

The official Senate register records the 21 September extension to 60 days and a 17 October 2026 deadline. Draft status is retained.

RO01
2026-09-23historical correction

Consultation end date corrected

The official consultation deadline was extended to 18 June 2026. No final enactment or primary September parliamentary record is inferred.

BG01
2026-09-23newly verified existing provisions

Full 2026 data period, eight-day response and filing ambiguity exposed

The complete official regulations replace the prior generic register-only entry. Calendar 2026 and the eight-day request response are explicit. The June versus 14-working-day submission provisions are kept visibly unresolved.

MT01MT02
2026-09-23newly verified existing policy detail

Planned JMHZ reuse made explicit

The official Cabinet announcement supports planned reuse for monitoring. Proposed 2028/2031 reporting years are shown at year precision. Current monthly infrastructure is not falsely labelled a complete or final PTD output.

CZ01
2026-09-23guidance clarification

Component mapping remains pending

Detailed register guidance does not mean every component mapping is final. The proposed legislative status and conditional first-filing dates are retained.

FI02
2026-09-23technical clarification

SDUP kept separate from SAM

January 2027 data and first submission in February 2027 are retained. A separate planned deadline must not be replaced with SAM’s ordinary date.

LT03
EU-27 · CELEX 32023L0970

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Request a review of your implementation scope. This status is not legal advice.

EUR-Lex · 2026-09-24
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27Countries
111Verified source title
83Audit timeline
352Team tasks
15Transposition status · EUR-Lex
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Countries
CountriesImplementation statusTransposition statusAudit timeline / Team tasksRecommended next steps
Austriaregister partial 17EUR-Lex 2 / 10
Recommended next steps

Partial/regional implementation: Upper Austria completed its 2026 equal-treatment amendment, published on 30 July. This is not confirmation of comprehensive Austrian private-sector implementation.

Establish whether the legal employer falls within the regional public-service scope. Verify the signed instrument and the separate federal/private-sector position before applying any date.

Verified source title
Belgiumregister preparation 6EUR-Lex 1 / 10
Recommended next steps

BE-MAGIC methodology work verified; a single comprehensive federal commencement date is not verified here.

Separate federal/private-sector, regional/community public-sector and collective-agreement duties. Use classification work without treating it as a filing rule.

Verified source title
Bulgariaregister draft 12EUR-Lex 2 / 10
Recommended next steps

Official draft consultation included an extended deadline of 18 June 2026. The reported 11 September Parliament submission remains watch-stage evidence: the primary bill record is not verified here.

Resolve the exact National Assembly bill ID and primary text before upgrading any employer obligation, commencement date or reporting rule from watch-stage evidence.

Verified source title
Croatiaregister preparation 0EUR-Lex 1 / 10
Recommended next steps

Ministry describes Labour Act alignment as ongoing and has released a voluntary evaluation methodology.

Use the free methodology for preparation; verify adopted law and filing instructions separately.

Verified source title
Cyprusregister draft 0EUR-Lex 1 / 10
Recommended next steps

Official pay-transparency consultation verified; final enacted text not verified.

Track the Department of Labour Relations and Gazette for scope, disclosure timing and reporting procedures.

Verified source title
Czechiaregister draft 31EUR-Lex 3 / 10
Recommended next steps

The 31 August Cabinet bill announcement expressly describes intended reuse of JMHZ data. The PTD bill remains a proposal in this reviewed source; final passage and output specifications are not established.

Ask payroll for current JMHZ data, native field mapping and correction history, while separately tracking the final PTD law and authority output instructions. Do not assume that existing monthly reports already satisfy the proposed PTD report.

Verified source title
Denmarkregister draft 0EUR-Lex 2 / 10
Recommended next steps

Official draft consultation names 1 January 2027 as proposed commencement.

Do not treat the consultation metadata as an enacted effective date; test the final employee-count and reporting model.

Verified source title
Estoniaregister partial 18EUR-Lex 2 / 12
Recommended next steps

2026 amendments have staged commencement; prospective consolidation includes January 2027 provisions.

Separate the July provisions from January provisions and verify the remaining Directive implementation; avoid applying the future consolidated text wholesale.

Verified source title
Finlanddossier draft 0EUR-Lex 5 / 10
Recommended next steps

Detailed register instructions exist, but the new framework remains dependent on HE129/2026.

Use the detailed country dossier; do not freeze proposed rules as final law.

Verified source title
Franceregister draft 0EUR-Lex 1 / 10
Recommended next steps

Government bill no. 944 was deposited in the Senate on 10 September 2026 under accelerated procedure. The existing equality-index regime remains current law; the PTD package is still draft.

Track Senate amendments, enactment and commencement decrees. Prepare recruitment range/salary-history controls, employee-response design and 50+ reporting categories without treating draft timings as binding.

Verified source title
Germanyregister unverified 0EUR-Lex 1 / 10
Recommended next steps

Full current transposition status not resolved against a final new instrument in this edition.

Obtain current EntgTranspG and amending acts; do not infer that the Directive’s 100-worker reporting threshold replaces domestic rules.

Verified source title
Greecedossier staged 5EUR-Lex 6 / 14
Recommended next steps

Enacted, with the core transparency provisions deferred to 1 November 2026.

Use the detailed dossier; confirm first reference-period interpretation and final filing specification.

Verified source title
Hungaryregister unverified 0EUR-Lex 1 / 10
Recommended next steps

Comprehensive current instrument and authority data specification not verified.

Legal owner to confirm the current Gazette/database and employment/equality rules before local deployment.

Verified source title
Irelandregister unverified 0EUR-Lex 1 / 10
Recommended next steps

Existing annual gap-reporting framework and portal development verified; full PTD enactment not verified.

Preserve June snapshot/12-month data and November publication process; independently confirm mandatory 2026 portal submission basis.

Verified source title
Italydossier enacted 1EUR-Lex 7 / 14
Recommended next steps

Decree 96/2026 is operative. Keep the existing >50 biennial return separate.

Use the detailed dossier; obtain Article 9 decrees and final new export rules, not the old report schema alone.

Verified source title
Latviaregister preparation 0EUR-Lex 1 / 10
Recommended next steps

Ministry FAQ updated 12 August 2026 describes a separate law under preparation.

Use the ministry’s training material; verify the final law, dates and data model before production.

Verified source title
Lithuaniadossier staged 25EUR-Lex 7 / 15
Recommended next steps

Phased enacted package; monthly SDUP data from January 2027 precedes annual reports.

Implement January 2027 monthly data collection independently of the later annual report.

Verified source title
Luxembourgregister unverified 0EUR-Lex 1 / 10
Recommended next steps

Comprehensive new instrument and production schema not verified.

Check Legilux and labour/equality authorities; keep any voluntary tools distinct from statutory filings.

Verified source title
Maltaregister enacted 1EUR-Lex 4 / 10
Recommended next steps

L.N.173/2026 explicitly uses calendar 2026 pay for the first 150+ reporting cycle and requires a written employee-information response within eight days. Two submission-timing clauses need authoritative reconciliation.

Preserve the complete 2026 pay/time population and implement the eight-day response workflow. Ask the monitoring body to reconcile regulation 9(5) with 9(2)–(4) before fixing a filing calendar.

Verified source title
Netherlandsregister draft 0EUR-Lex 4 / 10
Recommended next steps

Bill 36.949 remains pending in the Tweede Kamer. The debate calendar now shows Week 50 of 2026 (7–13 December), replacing the inherited Week 02 of 2027 schedule.

Recheck the parliamentary calendar and any amendments; retain the earlier 1 January 2027 target as a proposal, not an enacted commencement. Final commencement requires the prescribed royal-decree route.

Verified source title
Polanddossier partial 10EUR-Lex 4 / 10
Recommended next steps

Recruitment rules are binding; the comprehensive UC127 package remains a proposal in the reviewed record.

Maintain current recruitment compliance; reconcile final reporting dates and six-month commencement before implementation.

Verified source title
Portugalregister draft 0EUR-Lex 3 / 10
Recommended next steps

BTE Separata 26/2026 published an official draft proposal on 5 August 2026 for partial PTD transposition. Public appraisal followed; final legislation has not been verified as enacted.

Track submission/approval of the final law and any implementing technical instructions. Prepare for the draft’s 50+ reporting perimeter and two-month information workflow, but keep all dates labelled as proposed.

Verified source title
Romaniaregister draft 27EUR-Lex 4 / 10
Recommended next steps

L 445/2026 remains in urgent Senate committee procedure. On 21 September the Senate extended the review period; the tacit-adoption marker is now 17 October 2026, not 2 October.

Track committee reports and final passage. Do not use the 17 October parliamentary deadline as a payroll, disclosure or employer-reporting deadline.

Verified source title
Slovakiadossier enacted 21EUR-Lex 8 / 15
Recommended next steps

Act 76/2026 is in force. The first reporting window is August–December 2026.

Use the detailed dossier; retain first-period data and representative approvals, obtain production filing format.

Verified source title
Sloveniaregister preparation 16EUR-Lex 1 / 10
Recommended next steps

Official PAY DAY support/tool project verified; comprehensive enacted law not verified.

Training and tool-development dates are not employer filing dates; verify final statutory and technical rules.

Verified source title
Spainregister draft 10EUR-Lex 1 / 10
Recommended next steps

RD 902/2020 and the official job-evaluation procedure remain current foundations. An official Ministry consultation confirms a Royal Decree project to transpose Directive 2023/970; final enactment is not yet verified.

Track publication of the Royal Decree text, final approval and implementing/reporting specifications. Continue applying existing remuneration-register and pay-audit duties independently of the draft.

Verified source title
Swedenregister preparation 33EUR-Lex 1 / 10
Recommended next steps

Government has instructed continued implementation preparations; a new complete operative regime is not verified.

Retain existing equality/pay-survey processes; DO assignment deadline is not an employer commencement date.

Verified source title
ACLASA PULSE · Overview

Overview

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ACLASA Pay · Countries ↗
ACLASA PULSE · Project

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