The EU's Pay Transparency Law Is Five Months Late. Here Is What You Can Ask Anyway.

The EU's Pay Transparency Directive gave all 27 member states until June 7, 2026 to turn it into national law. Five months on, five of them have passed new legislation to do it: Italy, Slovakia, Greece, Malta and Lithuania. Greece's took effect on November 1.

If you are applying for a job in one of those countries, you now have a legal right to the starting pay or its range before you negotiate, and the employer is barred from asking what you earn now.

If you are applying anywhere else in the EU, you very likely do not have those rights yet, whatever you read in June. The directive itself gives you nothing directly. Its last article says so in one sentence: "This Directive is addressed to the Member States." Your rights are whatever your own country's law says, and in most of the EU that law has not been written.

What the directive asks every country to give you

Article 5 is the part that reaches a job seeker. Applicants get the right to receive, from the prospective employer, "the initial pay or its range," set on objective, gender-neutral criteria, plus the relevant terms of any collective agreement that applies to the position. That information has to arrive in a way that allows "an informed and transparent negotiation on pay, such as in a published job vacancy notice, prior to the job interview or otherwise."

The same article says an employer "shall not ask applicants about their pay history during their current or previous employment relationships." Job ads and job titles have to be gender-neutral.

Once you are hired, Article 7 lets you request your own pay level and the average pay levels, broken down by sex, for workers doing the same work as you or work of equal value. The employer has two months at most to answer, and your contract cannot stop you from disclosing your own pay to enforce equal pay.

That is the floor. Each country can go further, and the five that have legislated did not all write the same thing.

Where it is law, as of late October

• Italy. Legislative Decree 96 of May 7, 2026, in force since June 7. Italy is stricter than the directive on timing: the pay or range goes in the job advertisement itself. Its ban on the pay question also covers an employer getting the answer "indirectly," through a recruiter or agency it has hired to run the selection. Once you are employed, you can ask for the average pay by sex for your category once a year, with a written answer due within two months.
• Slovakia. Act No. 76/2026, in force since June 7. The starting pay or range has to come before the job interview or before the contract, and an employer that prints it in the published job offer has met the duty. It may not demand what you earn from your current or previous employers.
• Greece. Law 5316/2026, in force since November 1, according to the labor ministry's circular of October 7. The information comes "in reasonable time before the interview," in writing or orally, and the circular names job ads and posts on professional networking sites as ways to give it. Neither the employer nor anyone acting for it may ask about your pay history.
• Malta. Legal Notice 173 of 2026. Malta copied the directive's rights but not its timing: the information is due "prior to the conclusion of the recruitment process," which can come well after the interview. Once you are hired, though, Malta moves fast: an employer has eight days to answer your request for pay information.
• Lithuania. It amended its labor code for the directive, by law No. XV-969, and notified the Commission in June.

Poland sits halfway. A labor code amendment in force since December 24, 2025 puts the starting pay or range in the job ad, or before the interview, or at the latest before the job begins. It also takes pay out of the employment history an employer is allowed to ask you for. That amendment covers recruitment only. The rest of the directive, including the right to compare your pay once you are hired, is not in it.

The other twenty-one

EUR-Lex, the EU's official legal database, records the measures each country has notified as transposing a directive. For this one, as of October 24, it lists measures from 16 member states, the six above included. That count flatters the picture.

Notification is a government telling the Commission which laws it believes do the job, and those can be laws that were already on the books. Spain notified its 2007 equality act. Sweden notified laws on workplace codetermination and union representatives from the 1970s. Belgium's entries are all regional, from Flanders, Brussels, Wallonia and the French-speaking community, and Austria's come entirely from its states. Most of what the remaining countries on the list notified is existing employment and equality law.

Eleven member states have notified nothing at all: Germany, France, the Netherlands, Ireland, Denmark, Finland, Portugal, Croatia, Hungary, Luxembourg and Cyprus. France's government presented its bill on September 10. A bill is not a law, and you cannot cite one to an employer.

There is no sign of enforcement yet, either. The Commission publishes notices listing the countries it is pursuing for failing to transpose directives on time. Its notices of July 15 and September 25 do not include this one.

And if you are job hunting in the UK, none of this applies. The UK left the EU in 2020, three years before the directive was adopted.

What to do with this

In Italy, Slovakia, Greece or Malta, ask for the range, and say why. You are not making a demand. You are asking for something the law says you are owed, and a hiring manager who knows the rules will answer. In Italy, a job ad without it has already missed the employer's obligation, which tells you something about the employer before you have spoken to anyone.

When the current salary question comes, you can decline it. In those four countries the employer is not allowed to ask, and in Poland it cannot require an answer. Say what you expect the role to pay instead. In Italy and Greece the rule holds when the question comes from a recruiter working for the employer, too.

Everywhere else in the EU, ask anyway. You have no legal right to an answer, but "what is the range for this role?" is a normal question, and an employer that will eventually have to answer it has little reason to refuse. How readily the answer comes is information in itself.

Once you are hired in Italy, Slovakia, Greece or Malta, use the comparison right. The average pay by sex for your category of work is a figure nobody hands you, and it is the closest you will get to knowing what the people doing your job are paid. The directive caps the wait at two months. Malta made it eight days.

The June deadline was a date in Brussels. For a job seeker, the date that counts is the one in your own country's law, and for most of the EU that date has not been set. If you are comparing jobs across the EU, check which country's law you are applying under before you decide how hard to push.

If you are also applying in the United States, the rules there come state by state, and I went through what the state salary transparency laws require earlier this year.

Don't apply blind. It's your turn to do the screening.

Sources, read October 24, 2026: Directive (EU) 2023/970, Articles 2, 5, 7, 34 and 37, from the Official Journal text published by the EU Publications Office; the national transposition measures recorded for the directive in EUR-Lex, read through the Publications Office's database; Italy's Legislative Decree 96/2026 in the Gazzetta Ufficiale (Serie Generale n. 125, June 1, 2026), Articles 5 and 7; Slovakia's Act No. 76/2026 on Slov-Lex, Section 4; Malta's Legal Notice 173 of 2026 on legislation.mt, regulations 4 and 6; Greece's labor ministry circular 26923 of October 7, 2026 on Law 5316/2026; Poland's Act of June 4, 2025 amending the Labor Code (Dziennik Ustaw 2025, item 807); the French government's statement of September 10, 2026; and the Commission's transposition notices of July 15 and September 25, 2026. Lithuania's amending law is listed in EUR-Lex; its text is not described here.