EU Pay Transparency Directive: Where Do CEE Countries Stand?

Remuneration has long since ceased to be merely a matter for the payroll department. It is linked to the design of HR processes, equal pay for women and men, job evaluation and the building of trust between employers and employees. The EU Pay Transparency Directive introduces rules on recruitment, employees’ access to pay information, and the assessment and reporting of the gender pay gap. Companies must therefore review not only their existing procedures but also their overall approach to people management

Although the directive establishes a common legislative framework, individual countries differ in how they implement it and in the preparedness of employers. How are the new rules being put into practice in Slovakia, Hungary, Croatia and Slovenia? We have looked at current developments, companies’ experiences and the challenges they face during implementation.

Slovakia: initial practical experience

In Slovakia, the rules came into force on 7 June 2026, making it one of the first countries in the region where their practical implications can be observed. Initially, companies viewed pay transparency primarily as a new legislative and administrative obligation. Gradually, however, they are realising that the preparation process also raises broader questions concerning remuneration systems, career progression, job evaluation and communication with employees.

Larger companies and international groups are showing the greatest interest in preparing for this, as they analyse their pay structures and prepare for future reporting obligations. In smaller firms, on the other hand, we often encounter the view that the issue does not concern them, as they will not be subject to mandatory reporting. There is also a widespread misconception that, if employees do not complain about their pay, pay disparities are not a concern for the company. However, transparency also applies to recruitment, informing job applicants and establishing objective pay rules, in every organisation regardless of size.

The challenge often lies not in the pay analysis itself, but in identifying comparable job roles and assessing whether they involve the same work or work of equal value. The job evaluation methodology published by the Ministry of Labour, Social Affairs and Family of the Slovak Republic can serve as a useful guide. At the same time, companies need high-quality HR and pay data, correctly set pay bands and objective remuneration criteria. Collaboration between experts from HR, payroll, legal and finance departments, together with company management, is key to ensuring that remuneration rules are set consistently, objectively and clearly.

Hungary: companies’ preparedness varies significantly

According to the experience of the Human Capital team at Grant Thornton Hungary, companies are paying increasing attention to pay transparency, but their level of preparedness varies significantly. Some have already launched comprehensive programmes to review their remuneration systems and job roles, whilst others are still assessing their procedures or awaiting further details of Hungarian legislation. It is not just the size of the company that matters, but above all management support, the maturity of HR systems and the strategic priority the organisation attaches to the issue.

Many companies regard HR and payroll data as a sound foundation. Greater differences lie in the documentation of job roles and the methodologies used to evaluate them, particularly where job classification has evolved according to different criteria. Some companies assess the gender pay gap regularly, whilst others do so only occasionally. Expectations also vary regarding the costs of adjusting pay, ranging from significant to none at all. Employers fear internal tension when pay differences become more visible, but some see this as an opportunity for fairer pay and to strengthen employee trust.

One area that remains inadequately addressed is the training of managers, who often lack the information needed to answer employees’ questions. Companies seek external support for job evaluation and job architecture, setting pay structures and bands, analysing the gender pay gap, ensuring legal compliance, training managers and internal communication. As in Slovakia, objective job evaluation, reliable data and transparent rules are key. Many steps can be taken right now.

Croatia: preparation is more important than waiting for the law

The deadline for transposing the directive expired on 7 June 2026, but as of October 2026, Croatia had not yet completed the transposition. The existing legal framework already recognises the principle of equal pay and prohibits discrimination. However, the directive is expected to bring more structured processes and clearer information for both employers and employees. Until the rules are adopted, companies should distinguish between obligations that already apply and new requirements. International groups can draw on global remuneration frameworks, job grading systems and reporting processes.

However, pay data alone does not indicate readiness; this also depends on the maturity of HR processes, data quality and management buy-in. The most challenging task will be to identify roles that constitute work of equal value. It is not enough to compare job titles; skills, effort, responsibility and working conditions must also be taken into account. A pay gap does not automatically imply discrimination. However, unexplained differences must be thoroughly investigated, and conclusions should not be based solely on aggregate figures.

Communication is equally important. Even a technically sound analysis can cause confusion if managers are unable to explain how starting salaries are determined, what factors influence pay rises, and why colleagues’ pay varies. Transparency does not mean that everyone has the same salary, but that differences are based on clear, objective and non-discriminatory criteria. Companies can already review the quality of their HR and payroll data, update job descriptions, document the criteria for starting salaries, pay rises and variable remuneration, allocate responsibilities amongst HR, payroll, legal, finance and management, and draw up a communication plan. Getting started early allows time to identify any issues and make any necessary adjustments.

Slovenia: averages do not tell the whole story

Slovenia has missed the deadline for transposition. The draft bill was submitted to the Economic and Social Council in February 2026 and entered preliminary inter-ministerial consultation in May, but has not yet been published. The aim is to adopt the law by March 2027, though this is a planned, not a confirmed, deadline. The principle of equal pay is already guaranteed by Article 133 of the Employment Relationships Act (ZDR-1). The proposed legislation is intended to introduce more specific requirements regarding transparency and reporting on the gender pay gap.

According to Eurostat, the unadjusted gender pay gap in Slovenia stood at 8.0 % in 2024, which was below the EU average of 11.1 %. More recent data from the Slovenian Statistical Office (SURS) show that in October 2025 it stood at 3.3 %, whilst in October 2024 it was 5.0 %. However, the national average does not capture all the differences. In financial and insurance activities, the gap reached 22.2 % in October 2025, and in health and social care 17.2 %. Eurostat and SURS data relate to different periods and statistical coverage, so they cannot be directly compared.

A distinctive feature of the Slovenian labour market is the use of collective agreements and job classifications based on education, which, however, do not always correspond to the actual requirements of individual roles. Smaller employers, in turn, often have less formalised remuneration rules. In both cases, it is important to evaluate job roles according to objective, gender-neutral criteria. Practical support in this area is offered by the PAY DAY project, which provides advice and training and is developing a free online tool for evaluating and grouping roles of equal value.

Key takeaways

Experience from four countries shows that legislative readiness and employers’ actual readiness are not the same thing. Regardless of the current status of transposition, companies should focus on four areas:

• Data and criteria:
  ensure high-quality HR and payroll data and clearly document the criteria for determining starting salaries, pay rises and variable components of remuneration.
• Job evaluation: identify comparable roles based on objective and gender-neutral criteria.
• Analysis of remuneration: examine pay differentials and assess whether they are justified by objective and non-discriminatory factors, and not rely solely on aggregate figures.
• Communication: prepare managers to explain remuneration rules and answer employees’ questions.

The issue of remuneration transparency does not, however, concern only large companies. Requirements relating to recruitment, informing job applicants and setting remuneration objectively affect employers regardless of their size. Early preparation can make it easier for companies to meet their legislative obligations, whilst also helping to create a fairer, more consistent and more trustworthy remuneration system.