Transparent pay: How the new law is changing the rules on pay for men and women from June 2026

A new era of pay transparency in Slovakia begins on 7 June 2026. On 15 April 2026, the National Council of the Slovak Republic approved the Act on Equal Pay for Men and Women for Equal Work or Work of Equal Value, which transposes European Directive (EU) 2023/970 into our legal system.

The Directive focuses on combating pay discrimination and helping to eliminate the gender pay gap in the EU through pay transparency, which will make it possible to compare not only the pay of men and women, but also that of people in the same positions. The Directive fundamentally changes the rules of the game in the labour market. The principle of ‘equal pay for equal work’ will no longer be merely a stated objective, but a strictly monitored reality. Employers thus face one of the greatest legislative challenges and are set to face several new obligations.

 

Slovakia has one of the largest gender pay gaps in the EU

According to Eurostat data, Slovakia is among the EU countries with the highest gender pay gap, despite existing legislation prohibiting gender-based discrimination in pay. As stated in the explanatory memorandum, this situation is mainly due to:

• insufficient transparency in remuneration systems,
• the absence of objective and neutral criteria for assessing the value of work,
• insufficient monitoring of differences in remuneration.

 

Scope of the Act

The new legislation applies to: employment relationships governed by the Labour Code, as well as civil service relationships governed by specific regulations.

For the purposes of the Act, a judge is also considered an employee, with the court acting as their employer, and a prosecutor is considered an employee, with the public prosecutor’s office acting as their employer.

Conversely, the Act does not apply to: civil servant in public office and civil servants acting as statutory bodies, an employee performing work in the public interest who holds the position of a statutory body in an employment relationship following election by the National Council of the Slovak Republic, appointment by the President of the Slovak Republic, the Government of the Slovak Republic or a member of the Government of the Slovak Republic, or in a public-law institution.

 

Explanation of the term: Equal remuneration

As is clear from the explanatory memorandum, the term ‘remuneration’ is one of the most important terms in the entire Act. The right to equal remuneration should be observed with regard to pay, salary or any other monetary or non-monetary benefits that employees receive directly or indirectly from their employer in connection with their employment. In accordance with the Act, remuneration includes: the basic wage component, the minimum wage, or remuneration based on agreements for work performed outside an employment relationship, salary, as well as supplementary or variable components of remuneration.

Supplementary components of remuneration are those forms of remuneration which the employer provides on the basis of their own discretion, beyond the scope of statutory obligations. These include benefits, allowances or other monetary or non-monetary payments where the employer has discretion regarding their provision, amount, scope or conditions of receipt.

To ensure consistent reporting of the information required by law, the level of remuneration is expressed as gross annual remuneration, i.e. before deduction of the employee’s taxes and social security contributions, including all income from employment or a similar working relationship.

 

OVERVIEW OF KEY CHANGES AND DEADLINES RELEVANT TO EMPLOYERS:

 

I. Transparency towards job applicants

The issue of pay transparency begins as early as the recruitment phase, specifically when a job vacancy is advertised. The employer is obliged to ensure that the recruitment process is conducted in a manner that is not based on discrimination and does not undermine the right to equal pay.

Job advertisements and job titles must be formulated in a gender-neutral manner.

The new Act imposes an obligation on the employer to inform the job applicant of the starting salary or the range of starting remuneration for the position in question, as well as the relevant provisions of the collective agreement, if remuneration is governed by a collective agreement, and this must be done prior to the job interview or before concluding a contract with the employee. The obligation is deemed to have been fulfilled if the information is included in the published job advertisement. Until now (since 2018), employers were required to state the basic salary amount in the advertisement.

In order to prevent any historical pay inequalities between men and women from being carried over from one job to another, employers are prohibited from asking job applicants for information about their pay at their current or previous employer.

 

II. Transparency towards employees

Introduction of transparent remuneration structures

The introduction of transparent pay structures is the most important and strategically most challenging step in implementing the new law. Every employer, regardless of the size of the company, is obliged to introduce transparent remuneration structures that ensure compliance with the right to equal pay and enable an assessment of whether employees are in a comparable situation in terms of the value of the work performed. These must be based on objective and gender-neutral criteria.

The law does not directly prescribe to the employer which methodology to use when establishing a remuneration structure; the employer therefore has the freedom to choose the methodology that best suits the conditions and needs of their organisation. Remuneration criteria should take into account, in particular: complexity, responsibility, physical exertion, working conditions and other factors relevant to a specific job or position, whilst taking into account soft skills, which are primarily social and communication skills.

The criteria must be based on facts, not on prejudices and stereotypes; they must not be based directly or indirectly on gender and must be agreed with employee representatives, if such representatives are present at the employer’s premises. An agreement with employee representatives may also be reached through collective bargaining.

Remuneration structures may take the form of an internal regulation, a collective agreement, an employment contract or another document.

Furthermore, the employer is obliged to make available to employees the criteria on the basis of which

• employee remuneration is determined,
• the level of employees’ remuneration is determined, and
• employee remuneration is increased.

This information must be easily accessible to all employees, e.g. via the intranet.

The obligation to make the criteria for determining remuneration available does not apply to employers with fewer than 50 employees.

Employers must implement remuneration structures by 31 July 2026.

 

An employee’s right to information on pay

Remuneration transparency does not end with the signing of an employment contract. Employees acquire a legal right to request information on the level of their own pay and on the average pay levels of colleagues performing the same or comparable work (however, this does not apply if this information could be used to determine the pay level of another specific employee). This data will have to be categorised by gender.

Contractual confidentiality clauses that prohibit employees from discussing their pay are invalid. However, an employer may require employees to maintain confidentiality regarding the average pay levels of their colleagues.

The employer must provide information on the level of remuneration at the employee’s request within two months of the date of the request.

The employer shall provide information on the average level of remuneration for the first time for the year 2027.

 

III. Mandatory reporting on the remuneration of men and women

A requirement to report on the remuneration of men and women is introduced for employers with at least 100 employees, with the frequency depending on the size of the organisation. Companies with fewer than 100 employees may provide a remuneration report on a voluntary basis.

The pay report is prepared for the previous calendar year and sent to the Ministry of Labour, Social Affairs and Family of the Slovak Republic, generally by 15 April, and must include the following information:

1. a) the pay gap,
2. b) the pay gap in relation to supplementary pay components,
3. c) the median pay gap,
4. d) the median pay gap for supplementary pay components,
5. e) the proportion of men and women to whom the employer provides supplementary remuneration components,
6. f) the proportion of men and women in each pay quartile,

(g) the pay gap between employees by employee category, broken down by basic pay and additional pay components.

OVERVIEW OF REPORTING DEADLINES
Company with number of employees	Reporting frequency	First submission deadline
250 or more	Annually	7 June 2027
150–249	Every 3 years	7 June 2027
100–149	Every 3 years	7 June 2031
Less than 100	Voluntary	Unspecified

 

Note:

The Ministry of Labour, Social Affairs and Family of the Slovak Republic will not only oversee the entire system but will also work to raise awareness and provide assistance to employers in fulfilling their new obligations under the Equal Pay Act.

 

A pay gap of over 5% triggers an audit obligation

If the report finds that the pay gap between men and women exceeds 5% and cannot be justified by objective, gender-neutral criteria, the companies concerned will have to take measures in the form of a joint remuneration assessment carried out in cooperation with employee representatives. This obligation applies to companies with 100 or more employees. The aim of this measure is to initiate a process of reviewing and revising employers’ remuneration structures with a view to rectifying the gender pay gap.

The joint assessment must be carried out within 8 months of the remuneration report being submitted to the Ministry of Labour, Social Affairs and Family, in cooperation with employee representatives if they are present at the employer’s premises, and must include:

1. a) an analysis of the proportion of men and women in each category of employees,
2. b) information on the average remuneration levels of men and women and on the supplementary components for each category of employees,
3. c) differences in average pay levels between men and women in each category of employees,
4. d) the reasons for differences in average pay levels based on objective criteria not based on discrimination, where such differences exist,
5. e) the proportion of men and women who were affected by the increase in pay upon returning from maternity leave, paternity leave, parental leave, personal and full-time care of a sick family member or following a return from personal and full-time care of a natural person, where such an increase occurred in the relevant category of employees during the aforementioned periods,
6. f) measures to eliminate pay gaps within a reasonable timeframe, where such gaps are not justified on the basis of objective criteria that are not discriminatory,
7. g) an assessment of the effectiveness of measures to address pay gaps identified in previous joint pay reviews.

The employer is obliged to make the joint pay assessment available to employees and employee representatives, if any, and to provide it to the Ministry of Labour. Upon request, the employer shall also provide the joint remuneration assessment to the Labour Inspectorate and the Slovak Centre for Human Rights.

 

Right to compensation

The new law radically changes the position of an employee who has been the victim of gender discrimination in pay. If the company cannot prove that the difference (more than 5%) is justified, the employee is fully entitled to compensation – including full recovery of unpaid remuneration and related bonuses or benefits in kind.

Compensation must not be limited by any pre-determined cap; the employee is entitled to full compensation that places them in the position they would have been in had the discrimination not occurred.

Under the law, this compensation includes, in particular:

• compensation for unpaid remuneration,
• compensation for lost opportunities,
• compensation for non-pecuniary damage,
• compensation for other harm that is mentioned above, which may also have been caused by intersectional discrimination,
• interest on arrears of unpaid remuneration.

An employee (natural person) may exercise their right to compensation within a three-year limitation period from the date on which they became aware of the breach or could have become aware of it.

 

Reversed burden of proof: A risk for the unprepared

The Act introduces one exceptionally strict rule which, one might say, brings about a revolution in labour law litigation. In cases of litigation concerning pay discrimination, the burden of proof shifts to the employer; until now, it was usually borne by the employee. Under the new rules, therefore, the company will have to prove that pay differences are based on fair and neutral criteria.

 

Administrative offences

Breaches of employers’ obligations under the Equal Pay Act are punishable by fines ranging from €4,000 to €8,000.

 

OVERVIEW OF KEY DATES

OVERVIEW
Dates	Obligations
7 June 2026	Entry into force of the Equal Pay Act – employers face their first obligations/introduction of new rules for recruiting staff
30 June 2026	The Ministry of Labour, Social Affairs and Family will publish analytical tools and methodologies to assist employers
31 July 2026	Employers’ obligation to have remuneration structures in place
for 2027	At the employee’s request – the employer’s obligation to provide, for the first time, information on the employee’s pay level and on the average pay levels broken down by gender for the category of employees performing the same work or work of equal value as the employee
7 June 2027	Provide the first remuneration reports – companies with 150 or more employees
7 June 2031	Submit the first remuneration reports – companies with 100 to 149 employees

 

 

Why wait? Fortune favours the prepared

Implementing the Remuneration Transparency Act cannot be resolved with a single, hastily compiled report, but requires thorough, methodical preparation.

This process is not a project for a single department, but requires synergy across the entire organisation, as it involves a transformation of the whole company: from the payroll department, which provides accurate data for calculating complex remuneration, through the HR manager, whose role is to review the job catalogue and set gender-neutral criteria, and line managers who directly decide on the awarding of bonuses, right up to senior management, which bears full legal and financial responsibility for final compliance with legislation.

 

So where to start?

The first and most important step is to assess and categorise job roles based on gender-neutral criteria and carry out an internal pay audit (known as a Gap Analysis). Do not wait until the law comes into full effect. Now is the ideal time to retrieve pay data for the past period, factor in the value of all benefits, and check where the company exceeds the critical 5% threshold for pay differences, which will then need to be justified by objective factors.

The next step is to analyse recruitment processes (where there is an obligation to state the salary range in job advertisements or before the interview) and adapt them in line with the requirements of the new law. Subsequently, update internal guidelines and employment contracts (e.g. remove invalid clauses regarding salary confidentiality), ensure that employees are informed about the new rules, open a dialogue with employee representatives, and retrain line managers so that they can grasp the issues and the rationale behind objective differences in pay.

Employers should also start considering now the manner in which employees may request information in the future (the right to information regarding their own pay level as well as average pay levels), plan periodic reporting in line with the size of the company, and appoint a responsible person or implementation team within the company to oversee the entire process.

Identifying areas of risk well in advance will give companies the time they need to make strategic adjustments to pay scales and retrain management – without the stress, risk of legal disputes or damage to their reputation. Companies can thus turn a legal obligation into a competitive advantage today.