Last official-source check
Overview updated

89 document bodies / 110 bounded observations / 45 country and EU records; 30 scoped no-change findings; 5 unresolved checks. This is not a complete country-law review.

Open provenance and exact digests ↓
Historical content basis

Source check · 2026-10-07

The check covers only the listed sources and claims. It does not renew legal approval.

Checked at: · Content dates: 2026-10-03 / 2026-10-06

Not fully verified · Partial review

Other countries, national applicability and economic calculations were not reviewed.

Primary source

NZ · Equal Pay Act

No change in compared claims · Source edition: 2025-12-17

  • New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. Before a claim proceeds to pay-equity assessment, the employer must determine whether it meets the circumstances and requirements and has merit. Merit requires work performed by a workforce that has been at least 70% female over the past ten consecutive years, and reasonable grounds to believe the work was historically undervalued and remains subject to systemic sex-based undervaluation. Acknowledge receipt within five working days; decide within 60 working days, with a reasoned limited extension where allowed.
Primary source

EU · 2023/970 · Art.9 / Art.34

No change in compared claims · Source edition: 2023/970

  • The first Directive reporting date is 7 June 2027 for employers with at least 150 workers; the first 100-149 worker date is 7 June 2031, subject to national implementation.
  • National transposition: 2026-06-07 · Art.34(1)
Primary source

EU · 2026/470 · CSDDD

No change in compared claims · Source edition: 2026-02-26

  • Employees: >5 000 ∧ Net worldwide turnover: >EUR 1 500 000 000 · Art.2(1)(a)
  • National transposition: 2028-07-26 · Art.37(1)
  • National application: 2029-07-26 · Art.37(1)
  • Applies to financial years starting from: 2030-01-01 · Art.16
Primary source

EU · 2026/1563 · Art.2 / Art.3

No change in compared claims · Source edition: 2026-09-21

  • Future entry into force: 2026-11-10 · Art.3
  • Applies to financial years starting from: 2027-01-01 · Art.3
Primary source

EU · NIM

Not fully verified · Source edition: Not fully verified

  • Access failed; no conclusion about national measures.
Primary source

SK · 76/2026

Not fully verified · Source edition: 20260607

  • Dated official PDF read; comparison and current consolidation are not complete.
Primary source

IT · 96/2026

Not fully verified · Source edition: 96/2026 · 2026-05-07 · GU125 2026-06-01 · 2026-06-07

  • Only metadata and a menu were read; substantive provisions were not verified.
Primary source
Pay transparency • pay equity • world map

Pay Equity TrackerStart with the country. Then decide what to do.

A practical ACLASA map for pay transparency and pay equity. It shows countries with active rules, countries in transition and countries that need monitoring, without making the client dig through a long list first.

How to read this: green means the local file is ready; amber means a priority country brief; blue means monitored rules; violet and charcoal mean active non-EU logic.

Country map

A map for the first client conversation.

01see where a rule already matters
02open a short employer brief
03export the same data to XLSX

What changed. What to do next.

Compared with the previous production update:

The 8 October review covered all 45 country and EU records and all 110 governed source routes. It confirmed no newly enacted measure superseding the published positions. It corrected or clarified practical content for Austria, Malta, Greece, the United States, Canada, Brazil, Japan, Korea and other highlighted records. Five country records remain explicitly unverified where critical official bodies were unavailable or insufficient; their previous legal conclusions are retained rather than redated.

0 Changed10 Practical detail30 Rechecked5 Open verification

Practical detail

Austria

Current RIS GlBG section 63(6) was now retrieved: it says more than 150 workers; USP says at least 150. This resolves the previous access gap but leaves a source conflict to disclose. The governed B-GlBG is federal-sector law and is not evidence of economy-wide transposition.

Practical detail

Malta

LN 173/2026 text covers public/private employers and workers, with recruitment rules for applicants. Regulation 6 requires written response in eight days and retains data five years. Regulation 9 sets 2027/2031 reporting bands but also a fourteen-working-day submission clause; a single June filing date is incomplete without regulator clarification.

Practical detail

Greece

The official Parliament record was re-read on 8 October. It confirms Law 5316/2026, the 2 July vote and Gazette 105 A of 6 July 2026. The page does not provide a final article-by-article Gazette body, so the enacted status is confirmed while specific employer commencement and filing clauses remain open for local verification.

Practical detail

United States

Federal EPA covers substantially equal work and all compensation; Title VII generally starts at 15 employees. EEO-1 page says 2024 closed and 2025 updates pending. California 15+ in-post scales and 100+ pay-data duties are separate; 2025 reports were due 13 May 2026. DIR also confirms employee scale requests, anti-retaliation and wage recovery.

Practical detail

Canada

CHRC page modified 5 October 2026 still confirms federal average 10+ coverage, plan within 3 years, increases, annual statements and update at least every 5 years. Under-10 remains under CHRA section 11. LEEP separately covers specified federal 100+ entities; annual reports including wage gaps are due 1 June, with monetary penalties for reporting breaches.

Practical detail

Brazil

Law 14,611 articles 1–2 impose equal-value/same-function remuneration without a 100-worker exemption. The 100+ private-entity threshold concerns semiannual anonymised transparency reports in article 5, with mitigation plan and reporting penalty up to 3% payroll capped at 100 minimum salaries. Official MTE sources still show fifth report and sixth-report data window 3–31 August 2026.

All country findings and open points · 45

Every governed route was attempted. Relevant bodies were read for 89 unique registered sources; 21 source bodies remained unavailable or incomplete. A technical monitor separately returned 110 overdue review markers and 17 access, redirect or network warnings; those signals are not treated as legal findings. The journal distinguishes enacted law, proposals, guidance, notification metadata and unresolved scope. It is an operational source review, not employer-specific legal advice or a conformity decision.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
Articles 4–10 and 16–23 remain the EU baseline. The 7 June 2026 transposition deadline has passed; national application must be checked separately. NIM is a weekly notification register, not a completeness ruling.
Recommended next step
Assign national owners for candidate pay information, two-month requests, equal-value categories and reporting.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD · EU-NIM

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
The Ministry's dated Act 76/2026 text confirms current recruitment and own-pay information duties, first category averages for 2027, special first reports and reporting penalties. Slov-Lex's current consolidated body was not readable; later amendment completeness is not confirmed.
Recommended next step
Preserve August–December 2026 payroll categories and log own-pay requests with two-month and clarification deadlines.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: EU-PTD · EU-NIM · SK-MPSVR-GUIDANCE · SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyPractical detail
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
Original decree 96/2026 confirms public/private scope but excludes domestic and intermittent contracts. Article 4's CCNL presumption permits evidence of individual discrimination; article 7 limits requests to once annually. Article 9(4) implementing arrangements were not independently confirmed.
Recommended next step
Check contract exclusions and CCNL categories; operate written two-month responses and verify the article 9(4) decree before filing.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: EU-PTD · EU-NIM · IT-DLGS96 · IT-GU-96

Open country brief →
LithuaniaPractical detail
Previously
National amendments in force with staged operational dates
Finding
SADM confirms pay-system preparation by 31 December 2026 and monthly January 2027 Sodra data. The governed Sodra article is an older 8 May planning record describing June 2026; it is not current confirmation of the later timetable. XV-969 itself remains inaccessible.
Recommended next step
Finish equal-value groups and pay-system review by year-end; verify current Sodra instructions and enacted package before activating submissions.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: EU-PTD · EU-NIM · LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
HE 129/2026 remains a government proposal; Incomes Register guidance explicitly says the law is before Parliament. Its 2027/2030 payroll and 2028/2031 reports remain conditional. The 3 September evaluation model is optional guidance.
Recommended next step
Prepare data fields and test equal-value group mapping; retain proposal labels until adoption and commencement are confirmed.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; no proposal-based employer deadline is asserted.

Evidence: EU-PTD · EU-NIM · FI-HE129 · FI-STM-MODEL · FI-INCOMES-REGISTER

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
Senate bill 944 remains at first reading after 10 September deposit under accelerated procedure. Existing 50+ index duties remain: annual 1 March publication. Cabinet proposals for new recruitment/information/reporting rights are not enactment.
Recommended next step
Preserve current index evidence and remediation; map the proposed seven-indicator regime separately pending final law.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: EU-PTD · EU-NIM · FR-CABINET-PTD-BILL · FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
The 27 May coordination statement, 16 July government answer and 9 September opposition motion are legislative-preparation evidence. They do not establish enactment. Existing EntgTranspG equal-value and limited reporting duties were re-read independently.
Recommended next step
Maintain existing EntgTranspG controls and distinguish the opposition motion from a government bill; obtain current statutory scope for requests.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · DE-GOV-PTD-STATUS · DE-BT-GOV-ANSWER-21-7026 · DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
Gazette item 807 confirms recruitment pay information, gender-neutral wording and exclusion of pay history. PIP confirms commencement on 24 December 2025. UC127 remains a wider draft with planned Cabinet adoption in Q4 2026 and no completed implementation status.
Recommended next step
Audit current recruitment templates and delivery evidence; prepare UC127 categories and reporting data with a draft label.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: EU-PTD · EU-NIM · PL-DZ807 · PL-PIP · PL-PIP-RECRUITMENT-CURRENT · PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
BOE confirms RD 723/2026 has applied since 5 October. Article 7 requires new-hire information before employment starts and changes no later than their effective day; a five-day improvement target is not the statutory delivery deadline. Existing-worker requests have 30 working days. RD 902 remains the equal-pay layer; PTD completeness is unverified.
Recommended next step
Operate accessible pre-start information, delivery evidence, effective-day changes and a 30-working-day existing-worker request log.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Operational start: 5 October 2026. Existing-worker requests require a response within 30 working days. Keep the separate Pay Transparency Directive transposition review open.

Evidence: EU-PTD · EU-NIM · ES-RD902 · ES-RD902-CONSOLIDATED · ES-RD723 · ES-MITES-PTD-CONSULTATION

Open country brief →
NetherlandsRechecked
Previously
Government bill 36949 pending — no enacted Directive law confirmed
Finding
Bill 36949 still has voting and completion marked unfinished. Both chambers must approve; government page calls 1 January 2027 conditional. Scheduled December/January debates are legislative milestones, not employer deadlines.
Recommended next step
Prepare objective job valuation, candidate pay ranges and request controls; confirm the act before activating new legal dates.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; neither is an employer compliance deadline.

Evidence: EU-PTD · EU-NIM · NL-GOV-PTD-BILL · NL-TK-BILL-36949

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
FPS guidance confirms existing biennial pay-structure reports for covered average 50+ employers, abbreviated for 50–99 and full from 100. The report is discussed within three months of year-end and sent 15 days before the meeting; mediation is optional. Full federal/regional PTD implementation is not established.
Recommended next step
Calculate the covered headcount and financial-year cycle; schedule worker-representative receipt and discussion.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: EU-PTD · EU-NIM · BE-FPS-PAY-GAP

Open country brief →
SwedenPractical detail
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
DO still states that final Swedish legislation is unfinished. Existing annual pay mapping applies to all employers; documentation is required from ten workers. The government task due 1 November 2027 is a DO deadline, not a general employer reporting deadline.
Recommended next step
Complete annual equal-work/equal-value mapping with documented correction costs and timetable; keep upcoming PTD reports conditional.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · SE-GOV-PTD-RENEGOTIATION · SE-GOV-DO-PREPARATIONS · SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The parliamentary answer confirms a proposal for certain 50–99 employers with at least eight men and eight women in the same function, every three years from 2031. It describes existing 35+/10-and-10 statistics but does not enact repeal or new rules.
Recommended next step
Retain existing sex-disaggregated statistics; mark the 50–99 expansion and 2031 cycle as proposals pending an enacted act.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaPractical detail
Previously
8 measures notified; economy-wide completeness not established
Finding
Current RIS GlBG section 63(6) was now retrieved: it says more than 150 workers; USP says at least 150. This resolves the previous access gap but leaves a source conflict to disclose. The governed B-GlBG is federal-sector law and is not evidence of economy-wide transposition.
Recommended next step
Use the current statutory wording when assessing headcount; flag exactly 150 for local confirmation and correct the source title/scope.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: EU-PTD · EU-NIM · AT-RIS-GBG · AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
MPSV's government-approved proposal remains a proposal. It describes two-month information responses and 100+ reporting, first in 2028 for 150+ and 2031 for 100–149, with a 5%/six-month remediation trigger. The ministry page does not establish an enacted general commencement date.
Recommended next step
Maintain current equal-pay controls and map payroll fields to proposed categories; verify parliamentary adoption before activating the new regime.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · CZ-MPSV-PTD-BILL

Open country brief →
HungaryRechecked
Previously
Current transposition position unverified
Finding
Labour Code section 12 still requires equal treatment in pay, includes cash and in-kind remuneration, and lists equal-value criteria. New Directive recruitment, information, reporting and sanctions were not established.
Recommended next step
Document objective equal-value criteria and obtain the final current national implementing act.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
Law 60/2018 remains the enacted baseline: objective transparent pay policy; notified evaluation plan within 120 days, implemented over 12 months; CITE response within 30 days. August partial-transposition text remains explicitly a public-appraisal draft, including proposed recruitment, information and 50+ reporting rules.
Recommended next step
Keep Law 60/2018 controls and notification response timers; do not activate draft thresholds as law.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · PT-LAW60 · PT-BTE-SEPARATA26-2026

Open country brief →
IrelandRechecked
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The live Oireachtas bill record was re-read on 8 October. The Remuneration Information and Pay Transparency Bill 2023 still shows no enacted stage, while official 2026 parliamentary material records that full Directive transposition was delayed. Existing 50+ gender-pay-gap reporting remains active; a later complete government transposition act or mandatory portal commencement was not established by the reviewed sources.
Recommended next step
Continue governed 50+ reporting and obtain current enacted instruments and portal instructions before changing obligations.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · IE-EQUALITY-HEADS · IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
L445/2026 remains in permanent Senate committees. 17 October 2026 is the displayed tacit-adoption procedural milestone. No employer commencement or reporting date follows from it.
Recommended next step
Prepare equal-value/payroll data and recheck the parliamentary file at the 17 October milestone.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Legislative watch: 17 October 2026 tacit-adoption milestone; no employer duty starts on that date.

Evidence: EU-PTD · EU-NIM · RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
Consultation 12386 closed 18 June; response summary dated 11 August; final Council of Ministers act field remains blank. Consultation submissions and notified-measure counts cannot establish enacted comprehensive transposition.
Recommended next step
Obtain the final gazetted implementing text before assigning new national deadlines or penalties.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · BG-STRATEGY-CONSULTATION-12386 · BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
Ministry states Labour Act alignment is in progress. September FAQ evaluates the job rather than the incumbent. Free models are preparation tools; they establish no new employer reporting or recruitment deadline.
Recommended next step
Prepare job evaluation using objective job requirements and monitor final Labour Act amendments.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
The 11 September ministry work programme plans transposition by year end. This is a dated plan, without operative recruitment, worker-information, reporting or sanction clauses.
Recommended next step
Prepare the EU baseline data model and require a published national act before activating duties.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: EU-PTD · EU-NIM · SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
Ministry confirms 13 July recruitment amendments: written pay/range before first interview; no salary-history questions; no ban on discussing own pay; equal pay subject to objective gender-neutral justification. Current guidance distinguishes broader duties; April pause proposal is not an approved EU deadline extension.
Recommended next step
Record written pay/range delivery before interview and remove salary-history questions; keep wider national reporting verification pending.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EU-PTD · EU-NIM · EE-MKM-RECRUITMENT · EE-MKM-PAUSE · EE-MKM-CURRENT-STATUS

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
TAP 26-TA-700 remains labelled draft law. Official draft content is available after following the document link; its proposed rules must remain planning inputs rather than binding duties.
Recommended next step
Map payroll and equal-value data to the proposal; verify publication and commencement before activating it.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreecePractical detail
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
The official Parliament record was re-read on 8 October. It confirms Law 5316/2026, the 2 July vote and Gazette 105 A of 6 July 2026. The page does not provide a final article-by-article Gazette body, so the enacted status is confirmed while specific employer commencement and filing clauses remain open for local verification.
Recommended next step
Obtain the final Gazette text and review commencement and employer-specific reporting clauses.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The official Cyprus consultation record and attached revised 2026 bill were re-read on 8 October. The consultation is closed and the text remains identified as a bill whose commencement depends on future Gazette publication. The reviewed official material did not establish that publication or a final enacted measure, so current Cypriot law must still be applied until the Gazette record is verified.
Recommended next step
Obtain the revised bill and final Gazette record before specifying employer duties.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · CY-PTD-CONSULTATION

Open country brief →
MaltaPractical detail
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
LN 173/2026 text covers public/private employers and workers, with recruitment rules for applicants. Regulation 6 requires written response in eight days and retains data five years. Regulation 9 sets 2027/2031 reporting bands but also a fourteen-working-day submission clause; a single June filing date is incomplete without regulator clarification.
Recommended next step
Implement eight-day request response and five-year retention; preserve 2026 payroll and obtain written interpretation of regulation 9(5).
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: EU-PTD · EU-NIM · MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The official Chamber of Deputies record was re-read on 8 October. It documents the Labour Committee's 24 June 2026 discussion of Directive 2023/970 but does not identify a final enacted transposition act, employer threshold or commencement date. The record supports continued legislative monitoring, not new employer deadlines.
Recommended next step
Obtain current official implementing bill/act and retain the EU framework as readiness guidance.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: EU-PTD · EU-NIM · LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
GOV.UK confirms annual reporting for 250+ employees at snapshot. Action plans are currently voluntary; possible spring 2027 mandatory status is expressly subject to legislation. Existing Great Britain scope remains; this collection does not verify Northern Ireland or new recruitment/information duties.
Recommended next step
Keep mandatory report calendar and prepare an explicitly voluntary action plan with measurable owners and dates.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesPractical detail
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
Federal EPA covers substantially equal work and all compensation; Title VII generally starts at 15 employees. EEO-1 page says 2024 closed and 2025 updates pending. California 15+ in-post scales and 100+ pay-data duties are separate; 2025 reports were due 13 May 2026. DIR also confirms employee scale requests, anti-retaliation and wage recovery.
Recommended next step
Map recruitment locations, check California advertisements and retain 2025 certified reports; monitor EEO-1 opening.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-EEO1 · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
WGEA confirms 100+ private/Commonwealth reporting between 1 April and 31 May annually, CEO sign-off, employee/report access and governing-body delivery. Direct employers with 500+ select 3 targets and meet or improve them in 3 years; targets precede report lodgement. False or misleading information can trigger non-compliance and prosecution referral.
Recommended next step
Retain report delivery and target baseline/selection evidence; prepare the standard 2027 window.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaPractical detail
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
CHRC page modified 5 October 2026 still confirms federal average 10+ coverage, plan within 3 years, increases, annual statements and update at least every 5 years. Under-10 remains under CHRA section 11. LEEP separately covers specified federal 100+ entities; annual reports including wage gaps are due 1 June, with monetary penalties for reporting breaches.
Recommended next step
Confirm federal scope and individual plan start date; keep plan, increases and LEEP receipt under separate controls.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Confirm the entity-specific plan-update and current annual-statement or LEEP dates in the live regulator system; the reviewed pages did not support a universal 30 June 2027 or 4 September 2029 deadline.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilPractical detail
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
Law 14,611 articles 1–2 impose equal-value/same-function remuneration without a 100-worker exemption. The 100+ private-entity threshold concerns semiannual anonymised transparency reports in article 5, with mitigation plan and reporting penalty up to 3% payroll capped at 100 minimum salaries. Official MTE sources still show fifth report and sixth-report data window 3–31 August 2026.
Recommended next step
Check sixth-report employer account, publication evidence and mitigation plan; apply equal-pay controls below 100 too.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-LAW14611 · BR-MTE-EQUALITY-REPORT · BR-MTE-SIXTH-REPORT-2026

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
Official guidance confirms mandatory wage-gap and women-manager disclosure from 1 April 2026 for 101+ regularly employed workers; 101–300 add one indicator and 301+ one from each group. The regular-worker definition includes qualifying fixed-term/part-time workers. Disclosure is updated annually and supports comparable information for applicants.
Recommended next step
Validate worker denominator, wage components and annual publication; confirm fiscal-year-specific timing.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Publish annually after each applicable financial year; confirm the exact statutory publication window in current official guidance before setting the calendar.

Evidence: JP-MHLW-GPG · JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaPractical detail
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
Official statutory translation confirms article 3 general employee coverage, article 7 gender-neutral recruitment and article 8 equal value within the same business using skills, effort, responsibility and conditions, with worker-representative input. Article 17-3 separately requires covered employers to report workforce and income data; this does not establish universal public reporting.
Recommended next step
Document equal-value factors and representative consultation; verify Korean consolidated decree scope and affirmative-action reporting eligibility.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
Assigned parliamentary page returned no content. Official search extracts point to >518 annual internal/public reports and employee information, but linked guidance and enacted amendment could not be opened; the latter redirects to geographic maintenance. Preserve the prior position with explicit substantive-review gap.
Recommended next step
Obtain readable current Equal Pay Law and commission guidance before confirming current-cycle deadline and scope.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence:

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
2025 regulations were substantively reread: same, substantially same and equal-value work, objective factors and discrimination assessment are distinct from reporting scope. Live 2026 portal confirms 50+, organs of state and 1–49 designated by collective agreement; online EEA2/EEA4 due 15 January 2027 23:59. Manual/postal deadline passed 1 October; no changes after submission.
Recommended next step
Complete consultation, CEO approval and data reconciliation before final online submission; retain acknowledgement.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Online submission and corrections close on 15 January 2027 at 23:59; manual and posted filing is already closed.

Evidence: ZA-DEL-EE-REPORTING · ZA-EE-REGULATIONS-2025 · ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaOpen verification
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
PIB government explanation confirms section 3 prohibits gender discrimination, including transgender identity, in recruitment, wages and employment conditions for same or similar work. IndiaCode section body and linked ministry law PDF could not be fetched, so commencement and statutory exceptions were not substantively reconfirmed.
Recommended next step
Keep gender-neutral recruitment/pay controls; retrieve commencement notification and current implementing rules.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
MOM guidance confirms current merit-based recruitment and fair rewards by ability, performance, contribution and experience. February 2026 answer targets Workplace Fairness Act implementation at end-2027; historical bill factsheet describes initial <25 exemption with TGFEP continuing and review in five years. These sources do not prove a commenced exemption.
Recommended next step
Maintain merit-based pay/recruitment and confidential grievance handling; monitor commencement instruments.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP · SG-MOM-WFA-EXEMPTION

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
FOGE confirms 100+ workforce analysis; repeat after four years only if prior requirements were not met. Newly reaching 100 at start of year triggers analysis that year; evaluation and employee/shareholder information are separate steps. No new recruitment/information/reporting sanctions were established by this source.
Recommended next step
Record year-start headcount and prior result; derive the next date from the entity's evidence and arrange independent verification.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
Law 53/2026 is effective 1 September. 50+ average annual staff submit job classification, sex-based pay analysis and applicable remediation every three years; equality plan is prerequisite. Article 9 transition: three years from last certificate/confirmation, otherwise before 1 March 2027. Consolidated law provides supervision and daily fines; EEA incorporation remains unverified.
Recommended next step
Locate prior certification/confirmation and equality plan; calculate the entity deadline and prepare classification, payroll analysis and remediation.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-ALTHINGI-LAW150-CONSOLIDATED · IS-ALTHINGI-LAW53

Open country brief →
New ZealandOpen verification
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
Employment New Zealand response guidance confirms written acknowledgement in 5 working days, merit decision in 60 working days and reasoned extensions of up to 20 for one employer or 80 for multiple employers. It also requires union notification and privacy protection; discontinued claim may be challenged at ERA. Assigned consolidated Act could not be opened.
Recommended next step
Start claim clock on receipt, issue privacy-safe acknowledgement and document merit/extension reasons.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruOpen verification
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
Congress explanation reread confirms category/function schedules, non-discriminatory pay, worker notification of salary policy and non-discriminatory recruitment. It is dated January 2020; unavailable MTPE source prevents full current-law confirmation. No support for withdrawn August 2026 court claim was found in the assigned sources.
Recommended next step
Maintain category/function schedule and evidence of policy delivery; obtain current law/regulations and inspection penalty guidance.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
Law 20,348 confirms equal remuneration for same work, objective justified differences, written reasoned complaint/response within 30 days and role/function technical register at 200+. Directorate interpretation explains internal complaint followed by labour protection procedure. These sources do not turn same work into a universal equal-value/public-report regime.
Recommended next step
Audit internal complaint policy, 30-day response log and technical role register if 200+.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-LAW20348 · CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaOpen verification
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
Consolidated Law 25,877 articles 25–27 reread confirms annual confidential social balance at more than 300 workers, union delivery within 30 days, confidential ministry copy and first balance in year after threshold. Multiple collective agreements can require a balance for each regardless of workers covered. Equal-remuneration Law 20,392 body remained unavailable.
Recommended next step
Determine headcount and collective-agreement structure, prepare applicable balances and retain confidential union/ministry delivery evidence.
Suggested owner
Employer HR and payroll lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →
Earlier daily reviews

The 3 October differential review found no newly enacted measure superseding the governed positions. France's Senate dossier was updated on 3 October but Bill 944 remains at first reading. Poland's UC127, Finnish HE 129/2026, Dutch Bill 36949 and Romanian L445/2026 remain pending proposals. Spain's RD 723/2026 enters into force on 5 October, and South Africa continues to require online 2026 Employment Equity filing by 15 January 2027.

0 Changed2 Practical detail43 Rechecked0 Open verification
All country findings and open points · 45

All 45 tracker records and all 110 governed source routes were covered. The read-only monitor completed 98 routes without a warning and returned 12 access, redirect or network warnings; none is treated as proof of a legal change or absence of law. Official content was re-read for France, Poland, Spain, Finland, the Netherlands, Romania and South Africa. For other records, today's source-availability pass does not advance the substantive legal-review date. Poland's source reading is not represented as qualified human legal review or four-eyes approval.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
The official Incomes Register guidance was re-read on 3 October. It still says that the legislation is before Parliament and that instructions will be updated if the law changes. The proposed 2027/2030 payroll phases and first separate reports on 2 May 2028/2031 remain conditional on enactment.
Recommended next step
Keep payroll-field mapping and the proposed 2027 timetable labelled enactment-dependent; monitor Parliament and Finlex for the adopted text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; no proposal-based employer deadline is asserted.

Evidence: FI-INCOMES-REGISTER

Open country brief →
FrancePractical detail
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 3 October and now identifies the page as updated on 3 October 2026. Bill 944 remains at Senate first reading after its 10 September deposit under the accelerated procedure. The page-date change is recorded; no adopted act or employer commencement was confirmed.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep EU-readiness work active and monitor the federal legislative record for an actual government bill or enacted act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
The official Gazette amendment, Labour Inspectorate guidance and government register were re-read on 3 October. Binding recruitment duties remain active from 24 December 2025. UC127 remains a bill project, revision 2.0 dated 25 May 2026, with planned Cabinet adoption in Q4 2026 and a blank implementation-status field. This is not enacted law. The source reading is not represented as qualified human legal review or separate approval.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-DZ807 · PL-PIP-RECRUITMENT-CURRENT · PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
The official BOE record was re-read on 3 October. Royal Decree 723/2026 enters into force on 5 October 2026. Its written-employment-information duties implement Directive (EU) 2019/1152 and must not be presented as complete transposition of Directive (EU) 2023/970.
Recommended next step
Within five days, finalise an accessible article 3 information pack, evidence of delivery, change-notice workflow and a 30-working-day queue for existing-worker requests; do not wait for the official template. Keep RD 902 pay-register and equal-value controls active.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
Operational start: 5 October 2026. Existing-worker requests require a response within 30 working days. Keep the separate Pay Transparency Directive transposition review open.

Evidence: ES-RD723

Open country brief →
NetherlandsRechecked
Previously
Government bill 36949 pending — no enacted Directive law confirmed
Finding
The official government page was re-read on 3 October. It still says that both chambers must approve Bill 36949 and describes 1 January 2027 only as the planned start if the process proceeds as expected. No enacted act or current bill-based employer deadline was confirmed.
Recommended next step
Build a provisional 100+ headcount and reporting map, identify any 5% equal-value gaps and name the six-month remediation owner; keep the entire workflow disabled as a legal obligation until enactment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; neither is an employer compliance deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Continue annual pay mapping and track the government implementation timetable separately from the Ombudsman assignment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: SE-GOV-DO-PREPARATIONS

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Maintain readiness and watch Folketing and Lovtidende for a bill and final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: DK-FT-CONSULTATION

Open country brief →
AustriaRechecked
Previously
8 measures notified; economy-wide completeness not established
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Model the 100+ scenario for planning while keeping all dates conditional until the final act is published.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryRechecked
Previously
Current transposition position unverified
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep the existing equal-pay baseline in force and obtain a current Hungarian legislative confirmation before asserting new Directive duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep Law 60/2018 controls operational and track the separate Directive proposal to final publication.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: PT-LAW60

Open country brief →
IrelandRechecked
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Continue the existing 50+ reporting process and obtain direct official confirmation before changing the Directive implementation status.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: IE-GPG-PORTAL · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate file was re-read on 3 October. L445/2026 remains in work before the permanent committees. The displayed 17 October tacit-adoption date remains a parliamentary procedure marker, not enactment, commencement or an employer compliance deadline.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Legislative watch: 17 October 2026 tacit-adoption milestone; no employer duty starts on that date.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Track the official gazette and legislative file; keep implementation dates conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: BG-STRATEGY-CONSULTATION-12386

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Use the methodology as readiness guidance only and monitor the final Labour Act amendments.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: HR-MROSP-JOB-EVALUATION

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Track the project through Cabinet and Saeima stages; do not operationalise draft dates as binding.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: LV-TAP-26-TA-700

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review the revised bill for planning and wait for the enacted law and commencement notice before asserting duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep the EU baseline for readiness and obtain an official Luxembourg legislative file before asserting national duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilRechecked
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelRechecked
Previously
Annual reporting active for 519+ employers and specified entities
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaPractical detail
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The live government portal was re-read on 3 October. Manual and posted 2026 EEA2/EEA4 reports remain closed; covered employers must use the online route, complete corrections by 15 January 2027 at 23:59, obtain CEO approval and retain the acknowledgement. No changes are permitted after final submission.
Recommended next step
Move any unfinished filing to the online portal now. Reconcile EEA2/EEA4 figures, obtain CEO approval before final submission and save the acknowledgement.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Online submission and corrections close on 15 January 2027 at 23:59; manual and posted filing is already closed.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
The 3 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

The 2 October differential review found no newly enacted measure superseding the governed positions. Poland's official sources were deeply re-read and UC127 remains a draft. France's Senate dossier shows a 2 October page update but Bill 944 remains at first reading. South Africa now requires the online filing route after the manual/post deadline; Spain's RD 723/2026 takes effect on 5 October. Finnish HE 129/2026, Dutch Bill 36949 and Romanian L445/2026 remain pending proposals.

0 Changed2 Practical detail43 Rechecked0 Open verification
All country findings and open points · 45

All 45 tracker records and all 110 governed source routes were covered. The monitor completed 95 routes without a warning and returned 15 access, redirect or network warnings; none is treated as proof of a legal change or absence of law. Poland received a bounded legal-content review. Official content was re-read for France, South Africa, Spain, Finland, the Netherlands and Romania. For other records, today's source-availability pass does not advance the substantive legal-review date.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
The official Incomes Register guidance, updated on 30 September, was re-read on 2 October. It expressly says the legislation remains before Parliament. The proposed 2027/2030 payroll phases and first separate reports on 2 May 2028/2031 remain conditional on enactment; no adopted act was confirmed.
Recommended next step
Keep payroll-field mapping and the proposed 2027 timetable labelled enactment-dependent; monitor Parliament and Finlex for the adopted text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; no proposal-based employer deadline is asserted.

Evidence: FI-INCOMES-REGISTER

Open country brief →
FrancePractical detail
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier now identifies the page as updated on 2 October 2026. Bill 944 remains at Senate first reading after its 10 September deposit under the accelerated procedure. The source-date change is recorded; no adopted act or new employer commencement was confirmed.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep EU-readiness work active and monitor the federal legislative record for an actual government bill or enacted act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
The Gazette recruitment amendment, Labour Inspectorate guidance and government register were re-read on 2 October. Binding recruitment duties remain active from 24 December 2025. UC127 still appears as a government bill project, revision 2.0 dated 25 May 2026, with planned Cabinet adoption in Q4 2026 and no completed implementation status. It is not enacted law and the review does not establish complete transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-DZ807 · PL-PIP-RECRUITMENT-CURRENT · PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
The official BOE record was re-read on 2 October. Royal Decree 723/2026 was published on 15 September and enters into force on 5 October 2026. Its written-employment-information duties implement Directive (EU) 2019/1152; they must not be presented as complete transposition of Directive (EU) 2023/970.
Recommended next step
Within five days, finalise an accessible article 3 information pack, evidence of delivery, change-notice workflow and a 30-working-day queue for existing-worker requests; do not wait for the official template. Keep RD 902 pay-register and equal-value controls active.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
Operational start: 5 October 2026. Existing-worker requests require a response within 30 working days. Keep the separate Pay Transparency Directive transposition review open.

Evidence: ES-RD723

Open country brief →
NetherlandsRechecked
Previously
Government bill 36949 pending — no enacted Directive law confirmed
Finding
Official government and Tweede Kamer records were re-read on 2 October. Bill 36949 remains pending: debate is complete, voting is not complete, and plenary debates are scheduled for 7 December 2026 and 11 January 2027. The proposed 1 January 2027 start remains conditional on enactment.
Recommended next step
Build a provisional 100+ headcount and reporting map, identify any 5% equal-value gaps and name the six-month remediation owner; keep the entire workflow disabled as a legal obligation until enactment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; neither is an employer compliance deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Continue annual pay mapping and track the government implementation timetable separately from the Ombudsman assignment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: SE-GOV-DO-PREPARATIONS

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Maintain readiness and watch Folketing and Lovtidende for a bill and final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: DK-FT-CONSULTATION

Open country brief →
AustriaRechecked
Previously
8 measures notified; economy-wide completeness not established
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Model the 100+ scenario for planning while keeping all dates conditional until the final act is published.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryRechecked
Previously
Current transposition position unverified
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep the existing equal-pay baseline in force and obtain a current Hungarian legislative confirmation before asserting new Directive duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep Law 60/2018 controls operational and track the separate Directive proposal to final publication.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: PT-LAW60

Open country brief →
IrelandRechecked
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Continue the existing 50+ reporting process and obtain direct official confirmation before changing the Directive implementation status.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: IE-GPG-PORTAL · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate file was re-read on 2 October. L445/2026 remains before the permanent committees. The displayed 17 October tacit-adoption date is a parliamentary procedure marker, not enactment, commencement or an employer deadline.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Legislative watch: 17 October 2026 tacit-adoption milestone; no employer duty starts on that date.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Track the official gazette and legislative file; keep implementation dates conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: BG-STRATEGY-CONSULTATION-12386

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Use the methodology as readiness guidance only and monitor the final Labour Act amendments.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: HR-MROSP-JOB-EVALUATION

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Track the project through Cabinet and Saeima stages; do not operationalise draft dates as binding.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: LV-TAP-26-TA-700

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review the revised bill for planning and wait for the enacted law and commencement notice before asserting duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep the EU baseline for readiness and obtain an official Luxembourg legislative file before asserting national duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Review immediately: the planned 30 September 2026 review date has passed; repeat the review when a final act is published.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilRechecked
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelRechecked
Previously
Annual reporting active for 519+ employers and specified entities
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaPractical detail
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The live government portal was re-read on 2 October. Manual and posted 2026 EEA2/EEA4 reports are no longer accepted after 1 October. Covered employers must use the online route, complete corrections by 15 January 2027 at 23:59, obtain CEO approval and retain the acknowledgement; no changes are permitted after final submission.
Recommended next step
Move any unfinished filing to the online portal now. Reconcile EEA2/EEA4 figures, obtain CEO approval before final submission and save the acknowledgement.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Online submission and corrections close on 15 January 2027 at 23:59; manual and posted filing is already closed.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
The 2 October source-availability monitor covered this record's governed routes and did not establish a superseding legal change. This is an availability and differential check, not a new complete legal-content review. The governed position and its substantive legal-review date are retained.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

The 1 October deep review confirmed no newly enacted measure superseding the governed positions. South Africa is at its filing boundary: manual or posted 2026 EEA2/EEA4 reports are not accepted after 1 October, while online submissions and corrections remain open until 15 January 2027. Spain's RD 723/2026 written-employment-information duties start on 5 October. Dutch Bill 36949 and Romanian L445/2026 remain pending; the French and Finnish proposal files remain unconfirmed as enacted law.

0 Changed3 Practical detail36 Rechecked6 Open verification
All country findings and open points · 45

All 45 tracker records and all 110 governed source routes were covered. The read-only monitor attempted every route: 95 completed without a warning and 15 returned access restrictions, redirects or network warnings; none is treated as proof of a legal change or absence of law. Official content was re-read for South Africa, Spain, the Netherlands, Romania and Finland. France's government source remained access-restricted, so its proposal status is retained with that limitation. Other records keep their prior substantive legal-review dates; today's availability pass does not advance them.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
The official Finlex record was re-read on 1 October and still identifies HE 129/2026 as a government proposal. No adopted act or enacted commencement was confirmed. The linked government project route could not be reliably extracted during this run, so the timetable remains enactment-dependent.
Recommended next step
Keep payroll-field mapping and the proposed 2027 timetable labelled enactment-dependent; monitor Parliament and Finlex for the adopted text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; no proposal-based employer deadline is asserted.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
No enacted French pay-transparency measure was confirmed on 1 October. Automated access to the official government source returned HTTP 403, so the governed position for Bill 944 is retained from the last substantive review and is explicitly not presented as a fresh content verification.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
Bundestag document 21/7916 remains an opposition motion requesting implementation, not an enacted law. No new binding employer duty was confirmed.
Recommended next step
Keep EU-readiness work active and monitor the federal legislative record for an actual government bill or enacted act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainPractical detail
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
The official BOE text was re-read on 1 October. RD 723/2026 starts on 5 October, 20 days after publication. It requires written employment information within its scope and gives existing workers a request route with a 30-working-day employer response. It implements Directive 2019/1152 and is not proof that Directive (EU) 2023/970 has been fully transposed.
Recommended next step
Within five days, finalise an accessible article 3 information pack, evidence of delivery, change-notice workflow and a 30-working-day queue for existing-worker requests; do not wait for the official template. Keep RD 902 pay-register and equal-value controls active.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
Operational start: 5 October 2026. Existing-worker requests require a response within 30 working days. Keep the separate Pay Transparency Directive transposition review open.

Evidence: ES-RD902-CONSOLIDATED · ES-RD723 · EU-PTD

Open country brief →
NetherlandsPractical detail
Previously
Government bill 36949 pending — no enacted Directive law confirmed
Finding
The official Tweede Kamer record was re-read on 1 October. Bill 36949 remains pending: the debate stage is shown as completed, voting is not completed, and plenary debates remain scheduled for 7 December 2026 and 11 January 2027. These are parliamentary dates, not employer deadlines.
Recommended next step
Build a provisional 100+ headcount and reporting map, identify any 5% equal-value gaps and name the six-month remediation owner; keep the entire workflow disabled as a legal obligation until enactment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; neither is an employer compliance deadline.

Evidence: NL-GOV-PTD-BILL · NL-TK-BILL-36949

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
Government preparations continue; annual pay mapping remains relevant and the Equality Ombudsman task report is due 1 November 2027. No final enacted transposition measure was confirmed.
Recommended next step
Continue annual pay mapping and track the government implementation timetable separately from the Ombudsman assignment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: SE-GOV-DO-PREPARATIONS

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The official record still documents a draft consultation and ministerial answer, not an enacted implementation act. No new employer commencement date was confirmed.
Recommended next step
Maintain readiness and watch Folketing and Lovtidende for a bill and final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: DK-FT-CONSULTATION

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The government-approved ministry proposal still indicates a proposed 100+ reporting threshold, but enactment and a binding commencement date were not confirmed.
Recommended next step
Model the 100+ scenario for planning while keeping all dates conditional until the final act is published.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The current Labour Code equal-pay baseline was re-read. No accessible official source reviewed today confirmed a final national measure implementing Directive 2023/970.
Recommended next step
Keep the existing equal-pay baseline in force and obtain a current Hungarian legislative confirmation before asserting new Directive duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
Law 60/2018 remains the active verified equal-pay layer, including transparent remuneration-policy, evaluation/response and sanction mechanisms. No final Directive 2023/970 act was confirmed.
Recommended next step
Keep Law 60/2018 controls operational and track the separate Directive proposal to final publication.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The official Gender Pay Gap portal was inaccessible with HTTP 403 today. Existing 50+ reporting remains governed, but no later enacted Directive measure was confirmed from accessible official sources.
Recommended next step
Continue the existing 50+ reporting process and obtain direct official confirmation before changing the Directive implementation status.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: IE-GPG-PORTAL · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate file was re-read on 1 October. L445/2026 remains in work before the Senate's permanent committees. The 17 October tacit-adoption date is a parliamentary procedure marker, not enactment, commencement or an employer deadline.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Legislative watch: 17 October 2026 tacit-adoption milestone; no employer duty starts on that date.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
Consultation 12386 is closed and has a response summary, but the official record still does not show a final enacted act or binding employer start date.
Recommended next step
Track the official gazette and legislative file; keep implementation dates conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: BG-STRATEGY-CONSULTATION-12386

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The ministry states that Labour Act alignment is in progress and the published job-evaluation methodology is voluntary. No enacted Directive alignment was confirmed.
Recommended next step
Use the methodology as readiness guidance only and monitor the final Labour Act amendments.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: HR-MROSP-JOB-EVALUATION

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
Project 26-TA-700 remains a draft law in the official TAP system. Consultation deadlines have passed, but no enacted act is shown.
Recommended next step
Track the project through Cabinet and Saeima stages; do not operationalise draft dates as binding.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: LV-TAP-26-TA-700

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The consultation is complete and revised bill/result documents are published, but the official page does not show enactment or confirmed commencement.
Recommended next step
Review the revised bill for planning and wait for the enacted law and commencement notice before asserting duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgOpen verification
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The official committee record documents discussion and a request concerning the Directive. No implementing bill, enacted act or employer threshold was confirmed in accessible official records today.
Recommended next step
Keep the EU baseline for readiness and obtain an official Luxembourg legislative file before asserting national duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaPractical detail
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The official Employment Equity portal was re-read on 1 October. Its stated boundary is precise: manual and posted 2026 EEA2/EEA4 reports will not be accepted after 1 October. Online submissions and corrections remain open until 15 January 2027, require CEO approval, and cannot be changed after final submission.
Recommended next step
Treat 30 September as the last full preparation day for manual or post and dispatch no later than 1 October. Otherwise activate the online account, reconcile EEA2/EEA4, obtain CEO/accounting-officer approval, submit before 15 January and retain the acknowledgement plus submitted forms.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/postal acceptance boundary: 1 October 2026. Online submission and correction deadline: 15 January 2027.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 1 October differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

The 30 September deep review confirmed no newly enacted measure superseding the governed positions. Two employer clocks are now urgent: 30 September is the last full preparation day before South Africa stops accepting manual or posted 2026 EEA2/EEA4 reports after 1 October, and Spain's RD 723/2026 written-employment-information duties start on 5 October. Dutch Bill 36949, Romanian L445/2026, French Bill 944 and Finnish HE 129/2026 remain proposals, not current employer law.

0 Changed1 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 45 tracker records and all 110 governed source routes were covered. The read-only monitor attempted every route and recorded 15 access warnings with no critical or error finding. Official content was re-read for the moving Finland, France, Romania, Netherlands, Spain and South Africa files; an official-domain search for Spain's promised information template did not locate a confirmed publication. The remaining records retain their prior substantive legal-review dates; an availability check does not advance them and does not prove that law is unchanged.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
The official Finlex record was re-read on 30 September and still identifies HE 129/2026 as a government proposal. No adopted act or enacted commencement was confirmed; the timetable remains enactment-dependent.
Recommended next step
Keep payroll-field mapping and the proposed 2027 timetable labelled enactment-dependent; monitor Parliament and Finlex for the adopted text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; no proposal-based employer deadline is asserted.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 30 September. Bill 944 still shows its 10 September deposit and first reading under the accelerated procedure; the page remains last updated on 18 September and shows no adopted act or commencement.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
Bundestag document 21/7916 remains an opposition motion requesting implementation, not an enacted law. No new binding employer duty was confirmed.
Recommended next step
Keep EU-readiness work active and monitor the federal legislative record for an actual government bill or enacted act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
BOE was re-read on 30 September. RD 723/2026 still takes effect on 5 October 2026 and implements Directive 2019/1152, not complete Directive 2023/970 transposition. New relationships need article 3 information before work starts; existing workers can request missing information with a 30-working-day response. A bounded official-domain search did not locate the promised template, but BOE expressly says the template does not condition enforceability.
Recommended next step
Within five days, finalise an accessible article 3 information pack, evidence of delivery, change-notice workflow and a 30-working-day queue for existing-worker requests; do not wait for the official template. Keep RD 902 pay-register and equal-value controls active.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
5 October 2026 — five days remain at the review date.

Evidence: ES-RD902-CONSOLIDATED · ES-RD723 · EU-PTD

Open country brief →
NetherlandsPractical detail
Previously
Government bill 36949 pending — no enacted Directive law confirmed
Finding
The official Tweede Kamer record was re-read on 30 September. Bill 36949 remains pending, with plenary debates scheduled for 7 December 2026 and 11 January 2027. Its proposed 100+ reporting scope, 5% unexplained-gap remediation path within six months and Labour Inspectorate enforcement remain planning details, not current law.
Recommended next step
Build a provisional 100+ headcount and reporting map, identify any 5% equal-value gaps and name the six-month remediation owner; keep the entire workflow disabled as a legal obligation until enactment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; neither is an employer compliance deadline.

Evidence: NL-GOV-PTD-BILL · NL-TK-BILL-36949

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
Government preparations continue; annual pay mapping remains relevant and the Equality Ombudsman task report is due 1 November 2027. No final enacted transposition measure was confirmed.
Recommended next step
Continue annual pay mapping and track the government implementation timetable separately from the Ombudsman assignment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: SE-GOV-DO-PREPARATIONS

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The official record still documents a draft consultation and ministerial answer, not an enacted implementation act. No new employer commencement date was confirmed.
Recommended next step
Maintain readiness and watch Folketing and Lovtidende for a bill and final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: DK-FT-CONSULTATION

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The government-approved ministry proposal still indicates a proposed 100+ reporting threshold, but enactment and a binding commencement date were not confirmed.
Recommended next step
Model the 100+ scenario for planning while keeping all dates conditional until the final act is published.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The current Labour Code equal-pay baseline was re-read. No accessible official source reviewed today confirmed a final national measure implementing Directive 2023/970.
Recommended next step
Keep the existing equal-pay baseline in force and obtain a current Hungarian legislative confirmation before asserting new Directive duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
Law 60/2018 remains the active verified equal-pay layer, including transparent remuneration-policy, evaluation/response and sanction mechanisms. No final Directive 2023/970 act was confirmed.
Recommended next step
Keep Law 60/2018 controls operational and track the separate Directive proposal to final publication.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The official Gender Pay Gap portal was inaccessible with HTTP 403 today. Existing 50+ reporting remains governed, but no later enacted Directive measure was confirmed from accessible official sources.
Recommended next step
Continue the existing 50+ reporting process and obtain direct official confirmation before changing the Directive implementation status.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: IE-GPG-PORTAL · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate record was re-read on 30 September. L445/2026 remains in permanent committees. The displayed 17 October 2026 milestone is the extended tacit-adoption deadline, not employer commencement.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Legislative watch: 17 October 2026 tacit-adoption milestone; no employer duty starts on that date.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
Consultation 12386 is closed and has a response summary, but the official record still does not show a final enacted act or binding employer start date.
Recommended next step
Track the official gazette and legislative file; keep implementation dates conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: BG-STRATEGY-CONSULTATION-12386

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The ministry states that Labour Act alignment is in progress and the published job-evaluation methodology is voluntary. No enacted Directive alignment was confirmed.
Recommended next step
Use the methodology as readiness guidance only and monitor the final Labour Act amendments.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: HR-MROSP-JOB-EVALUATION

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
Project 26-TA-700 remains a draft law in the official TAP system. Consultation deadlines have passed, but no enacted act is shown.
Recommended next step
Track the project through Cabinet and Saeima stages; do not operationalise draft dates as binding.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: LV-TAP-26-TA-700

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The consultation is complete and revised bill/result documents are published, but the official page does not show enactment or confirmed commencement.
Recommended next step
Review the revised bill for planning and wait for the enacted law and commencement notice before asserting duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgOpen verification
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The official committee record documents discussion and a request concerning the Directive. No implementing bill, enacted act or employer threshold was confirmed in accessible official records today.
Recommended next step
Keep the EU baseline for readiness and obtain an official Luxembourg legislative file before asserting national duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The live Department of Employment and Labour portal was re-read on 30 September. The 2026 EEA2/EEA4 cycle is open for employers with 50+ workers, organs of state and 1–49 employers designated by collective agreement. Manual and posted reports will not be accepted after 1 October; online submission closes 15 January 2027 at 23:59 after consultation and CEO/accounting-officer approval.
Recommended next step
Treat 30 September as the last full preparation day for manual or post and dispatch no later than 1 October. Otherwise activate the online account, reconcile EEA2/EEA4, obtain CEO/accounting-officer approval, submit before 15 January and retain the acknowledgement plus submitted forms.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post cut-off: after 1 October 2026 (one day remains). Online close: 15 January 2027 at 23:59.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 30 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

The 29 September deep review confirmed no newly enacted measure superseding the governed positions. The immediate employer clock is now operational: South Africa stops accepting manual or posted 2026 EEA2/EEA4 reports after 1 October, while Spain's RD 723/2026 written-employment-information duties start on 5 October. Dutch Bill 36949 remains pending; its 100+ reporting, 5%/six-month remediation and enforcement model is planning detail, not current law.

0 Changed1 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 45 tracker records and all 110 governed source routes were covered. The read-only monitor reached 94 sources and recorded 17 access warnings with no critical or error finding. Official content was re-read for the moving Finland, France, Romania, Netherlands, Spain and South Africa files. The remaining records retain their prior substantive legal-review dates; an availability check does not advance them and does not prove that law is unchanged.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
The Finlex proposal record was re-read on 29 September and still identifies HE 129/2026 as a government proposal. The government project page returned a rate-limit response during the independent content check. No adopted act or enacted commencement was confirmed; the status remains pending with that access limitation disclosed.
Recommended next step
Keep payroll-field mapping and the proposed 2027 timetable labelled enactment-dependent; monitor Parliament and Finlex for the adopted text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; no proposal-based employer deadline is asserted.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 29 September. Bill 944 still shows its 10 September deposit and first reading under the accelerated procedure; the page remains last updated on 18 September and shows no adopted act or commencement.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
Bundestag document 21/7916 remains an opposition motion requesting implementation, not an enacted law. No new binding employer duty was confirmed.
Recommended next step
Keep EU-readiness work active and monitor the federal legislative record for an actual government bill or enacted act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
BOE was re-read on 29 September. RD 723/2026 still takes effect on 5 October 2026 and remains a written-employment-information layer implementing Directive 2019/1152, not proof of complete Directive 2023/970 transposition. New relationships need the article 3 information before work starts; existing workers can request missing information with a 30-working-day response. The official template does not condition enforceability.
Recommended next step
Within six days, finalise a mobile-accessible article 3 information pack, evidence of delivery, change-notice workflow and a 30-working-day queue for existing-worker requests; keep RD 902 pay-register and equal-value controls active.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
5 October 2026 — six days remain at the review date.

Evidence: ES-RD902-CONSOLIDATED · ES-RD723 · EU-PTD

Open country brief →
NetherlandsPractical detail
Previously
Government bill 36949 pending — no enacted Directive law confirmed
Finding
Official government and Tweede Kamer pages were re-read on 29 September. Bill 36949 remains pending, with plenary debates scheduled for 7 December 2026 and 11 January 2027. For planning only, the proposal uses 100+ reporting scope, a 5% unexplained-gap remediation path within six months and Labour Inspectorate enforcement. None is current law before enactment.
Recommended next step
Build a provisional 100+ headcount and reporting map, identify any 5% equal-value gaps and name the six-month remediation owner; keep the entire workflow disabled as a legal obligation until enactment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; neither is an employer compliance deadline.

Evidence: NL-GOV-PTD-BILL · NL-TK-BILL-36949

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
Government preparations continue; annual pay mapping remains relevant and the Equality Ombudsman task report is due 1 November 2027. No final enacted transposition measure was confirmed.
Recommended next step
Continue annual pay mapping and track the government implementation timetable separately from the Ombudsman assignment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: SE-GOV-DO-PREPARATIONS

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The official record still documents a draft consultation and ministerial answer, not an enacted implementation act. No new employer commencement date was confirmed.
Recommended next step
Maintain readiness and watch Folketing and Lovtidende for a bill and final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: DK-FT-CONSULTATION

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The government-approved ministry proposal still indicates a proposed 100+ reporting threshold, but enactment and a binding commencement date were not confirmed.
Recommended next step
Model the 100+ scenario for planning while keeping all dates conditional until the final act is published.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The current Labour Code equal-pay baseline was re-read. No accessible official source reviewed today confirmed a final national measure implementing Directive 2023/970.
Recommended next step
Keep the existing equal-pay baseline in force and obtain a current Hungarian legislative confirmation before asserting new Directive duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
Law 60/2018 remains the active verified equal-pay layer, including transparent remuneration-policy, evaluation/response and sanction mechanisms. No final Directive 2023/970 act was confirmed.
Recommended next step
Keep Law 60/2018 controls operational and track the separate Directive proposal to final publication.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The official Gender Pay Gap portal was inaccessible with HTTP 403 today. Existing 50+ reporting remains governed, but no later enacted Directive measure was confirmed from accessible official sources.
Recommended next step
Continue the existing 50+ reporting process and obtain direct official confirmation before changing the Directive implementation status.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: IE-GPG-PORTAL · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate record was re-read on 29 September. L445/2026 remains in permanent committees. The Senate approved extending the tacit-adoption period to 60 days on 21 September, and the displayed milestone remains 17 October 2026; it is a parliamentary deadline, not employer commencement.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Legislative watch: 17 October 2026 tacit-adoption milestone; no employer duty starts on that date.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
Consultation 12386 is closed and has a response summary, but the official record still does not show a final enacted act or binding employer start date.
Recommended next step
Track the official gazette and legislative file; keep implementation dates conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: BG-STRATEGY-CONSULTATION-12386

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The ministry states that Labour Act alignment is in progress and the published job-evaluation methodology is voluntary. No enacted Directive alignment was confirmed.
Recommended next step
Use the methodology as readiness guidance only and monitor the final Labour Act amendments.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: HR-MROSP-JOB-EVALUATION

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
Project 26-TA-700 remains a draft law in the official TAP system. Consultation deadlines have passed, but no enacted act is shown.
Recommended next step
Track the project through Cabinet and Saeima stages; do not operationalise draft dates as binding.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: LV-TAP-26-TA-700

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The consultation is complete and revised bill/result documents are published, but the official page does not show enactment or confirmed commencement.
Recommended next step
Review the revised bill for planning and wait for the enacted law and commencement notice before asserting duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgOpen verification
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The official committee record documents discussion and a request concerning the Directive. No implementing bill, enacted act or employer threshold was confirmed in accessible official records today.
Recommended next step
Keep the EU baseline for readiness and obtain an official Luxembourg legislative file before asserting national duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 30 September 2026 or earlier if a final act is published.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The live Department of Employment and Labour portal was re-read on 29 September. The 2026 EEA2/EEA4 cycle is open for employers with 50+ workers, organs of state and 1–49 employers designated by collective agreement. Manual and posted reports stop after 1 October; online submission closes 15 January 2027 at 23:59 after consultation and CEO/accounting-officer approval.
Recommended next step
If using manual or post, file within two days. Otherwise activate the online account, reconcile EEA2/EEA4, obtain CEO/accounting-officer approval, submit before 15 January and retain the acknowledgement plus submitted forms.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post cut-off: after 1 October 2026 (two days remain). Online close: 15 January 2027 at 23:59.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 29 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

The 28 September differential review confirmed no newly enacted measure superseding the governed country positions. Finland HE 129/2026 remains before Parliament, France bill 944 remains at first reading, Romania L445/2026 remains in Senate committees, and Dutch bill 36949 remains scheduled for plenary debate. Near-term employer controls remain South Africa on 1 October and Spain RD 723/2026 on 5 October.

0 Changed1 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 45 tracker records and all 110 governed source routes were covered. The read-only monitor reached 93 sources and recorded 17 access warnings with no critical or error finding. Official content was re-read for the moving Finland, France, Romania, Netherlands, Spain and South Africa files. The remaining records retain their prior substantive legal-review dates; an availability check does not advance them and does not prove that law is unchanged.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
Finlex and the official government project record were re-read on 28 September. HE 129/2026 remains a proposal delivered to Parliament on 9 July 2026; the government project still shows the matter in progress with a timetable through 1 January 2027. No adopted act or enacted commencement was confirmed.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 28 September. Bill no. 944 still shows only its 10 September deposit and first reading under the accelerated procedure; the dossier was last updated on 18 September and shows no adopted act or commencement.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
Bundestag document 21/7916 remains an opposition motion requesting implementation, not an enacted law. No new binding employer duty was confirmed.
Recommended next step
Keep EU-readiness work active and monitor the federal legislative record for an actual government bill or enacted act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
BOE was re-read on 28 September. No superseding act was confirmed. RD 902/2020 remains the binding equal-pay, remuneration-register, equal-value and applicable pay-audit layer. RD 723/2026 remains scheduled to take effect on 5 October 2026 as a separate written-employment-information layer that partially transposes Directive (EU) 2019/1152, not Directive (EU) 2023/970; Spain’s EU Pay Transparency completeness status therefore remains unverified.
Recommended next step
Maintain the RD 902/2020 remuneration register and applicable equality-plan pay audit; consult legal worker representatives at least ten days before creating or changing the register and retain the consultation evidence; confirm collective-agreement and autonomous-community effects locally. In parallel, map each RD 723/2026 item to the offer/contract information pack, payroll dictionary and delivery log, and test pre-start delivery, same-day change notices and the algorithmic-pay explanation.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
Operational by 5 October 2026. New-hire information before employment starts; changes no later than the day they take effect. Existing workers may request missing information under the transitional rule.

Evidence: ES-RD902-CONSOLIDATED · ES-RD723 · EU-PTD

Open country brief →
NetherlandsPractical detail
Previously
Government bill 36949 pending — no enacted Directive law confirmed
Finding
Bill 36949 remains pending. The official Tweede Kamer record now gives two concrete plenary milestones: 7 December 2026 and 11 January 2027. Both chambers must still approve the bill; no enacted national commencement was confirmed.
Recommended next step
Prepare equal-value criteria, payroll data, applicant-pay information and works-council/privacy involvement; assign legal watch for both plenary dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; these are not employer compliance deadlines.

Evidence: NL-GOV-PTD-BILL · NL-TK-BILL-36949

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
Government preparations continue; annual pay mapping remains relevant and the Equality Ombudsman task report is due 1 November 2027. No final enacted transposition measure was confirmed.
Recommended next step
Continue annual pay mapping and track the government implementation timetable separately from the Ombudsman assignment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: SE-GOV-DO-PREPARATIONS

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The official record still documents a draft consultation and ministerial answer, not an enacted implementation act. No new employer commencement date was confirmed.
Recommended next step
Maintain readiness and watch Folketing and Lovtidende for a bill and final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: DK-FT-CONSULTATION

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The government-approved ministry proposal still indicates a proposed 100+ reporting threshold, but enactment and a binding commencement date were not confirmed.
Recommended next step
Model the 100+ scenario for planning while keeping all dates conditional until the final act is published.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The current Labour Code equal-pay baseline was re-read. No accessible official source reviewed today confirmed a final national measure implementing Directive 2023/970.
Recommended next step
Keep the existing equal-pay baseline in force and obtain a current Hungarian legislative confirmation before asserting new Directive duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
Law 60/2018 remains the active verified equal-pay layer, including transparent remuneration-policy, evaluation/response and sanction mechanisms. No final Directive 2023/970 act was confirmed.
Recommended next step
Keep Law 60/2018 controls operational and track the separate Directive proposal to final publication.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The official Gender Pay Gap portal was inaccessible with HTTP 403 today. Existing 50+ reporting remains governed, but no later enacted Directive measure was confirmed from accessible official sources.
Recommended next step
Continue the existing 50+ reporting process and obtain direct official confirmation before changing the Directive implementation status.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: IE-GPG-PORTAL · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate record was re-read on 28 September. L445/2026 remains in permanent committees. The 60-day tacit-adoption period ends on 17 October 2026; this is a parliamentary milestone and does not activate an employer duty.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the revised 17 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
Consultation 12386 is closed and has a response summary, but the official record still does not show a final enacted act or binding employer start date.
Recommended next step
Track the official gazette and legislative file; keep implementation dates conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: BG-STRATEGY-CONSULTATION-12386

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The ministry states that Labour Act alignment is in progress and the published job-evaluation methodology is voluntary. No enacted Directive alignment was confirmed.
Recommended next step
Use the methodology as readiness guidance only and monitor the final Labour Act amendments.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: HR-MROSP-JOB-EVALUATION

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
Project 26-TA-700 remains a draft law in the official TAP system. Consultation deadlines have passed, but no enacted act is shown.
Recommended next step
Track the project through Cabinet and Saeima stages; do not operationalise draft dates as binding.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: LV-TAP-26-TA-700

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The consultation is complete and revised bill/result documents are published, but the official page does not show enactment or confirmed commencement.
Recommended next step
Review the revised bill for planning and wait for the enacted law and commencement notice before asserting duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgOpen verification
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The official committee record documents discussion and a request concerning the Directive. No implementing bill, enacted act or employer threshold was confirmed in accessible official records today.
Recommended next step
Keep the EU baseline for readiness and obtain an official Luxembourg legislative file before asserting national duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The official 2026 Employment Equity portal and Department guidance were re-read on 28 September. EEA2 and EEA4 reporting remains open for designated employers. Manual and posted reports are not accepted after 1 October 2026; online submission remains open until 15 January 2027 at 23:59. CEO or accounting-officer approval and the acknowledgement package remain required evidence. No superseding rule was confirmed.
Recommended next step
If filing manually, complete consultation, CEO or accounting-officer approval, final reconciliation and dispatch now. Otherwise use the online route, validate EEA2/EEA4, press submit and retain the acknowledgement letter and submitted forms.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual or posted filing: 1 October 2026. Online filing: 15 January 2027 at 23:59.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 28 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

The 27 September deep review found no newly enacted pay-transparency measure in the governed register. Practical movement: Dutch Bill 36949 is scheduled for plenary debate on 7 December 2026 and 11 January 2027. Near-term employer priorities remain South Africa's 1 October manual-filing cut-off and Spain's Royal Decree 723/2026 start on 5 October.

0 Changed1 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 45 tracker records and 110 governed primary sources were reviewed or access-checked. The final automated monitor reached 94 sources and recorded 17 access warnings with no critical or error finding. Access warnings are not legal conclusions.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
Finlex and the official government project record were re-read on 27 September. HE 129/2026 remains a proposal delivered to Parliament on 9 July 2026; the government project still shows the matter in progress with a timetable through 1 January 2027. No adopted act or enacted commencement was confirmed.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 27 September. Bill no. 944 still shows only its 10 September deposit and first reading under the accelerated procedure; the dossier was last updated on 18 September and shows no adopted act or commencement.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
Bundestag document 21/7916 remains an opposition motion requesting implementation, not an enacted law. No new binding employer duty was confirmed.
Recommended next step
Keep EU-readiness work active and monitor the federal legislative record for an actual government bill or enacted act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
BOE was re-read on 27 September. No superseding act was confirmed. RD 902/2020 remains the binding equal-pay, remuneration-register, equal-value and applicable pay-audit layer. RD 723/2026 remains scheduled to take effect on 5 October 2026 as a separate written-employment-information layer that partially transposes Directive (EU) 2019/1152, not Directive (EU) 2023/970; Spain’s EU Pay Transparency completeness status therefore remains unverified.
Recommended next step
Maintain the RD 902/2020 remuneration register and applicable equality-plan pay audit; consult legal worker representatives at least ten days before creating or changing the register and retain the consultation evidence; confirm collective-agreement and autonomous-community effects locally. In parallel, map each RD 723/2026 item to the offer/contract information pack, payroll dictionary and delivery log, and test pre-start delivery, same-day change notices and the algorithmic-pay explanation.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
Operational by 5 October 2026. New-hire information before employment starts; changes no later than the day they take effect. Existing workers may request missing information under the transitional rule.

Evidence: ES-RD902-CONSOLIDATED · ES-RD723 · EU-PTD

Open country brief →
NetherlandsPractical detail
Previously
Government bill awaits both chambers; start date conditional
Finding
Bill 36949 remains pending. The official Tweede Kamer record now gives two concrete plenary milestones: 7 December 2026 and 11 January 2027. Both chambers must still approve the bill; no enacted national commencement was confirmed.
Recommended next step
Prepare equal-value criteria, payroll data, applicant-pay information and works-council/privacy involvement; assign legal watch for both plenary dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Legislative watch: 7 December 2026 and 11 January 2027; these are not employer compliance deadlines.

Evidence: NL-GOV-PTD-BILL · NL-TK-BILL-36949

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
Government preparations continue; annual pay mapping remains relevant and the Equality Ombudsman task report is due 1 November 2027. No final enacted transposition measure was confirmed.
Recommended next step
Continue annual pay mapping and track the government implementation timetable separately from the Ombudsman assignment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: SE-GOV-DO-PREPARATIONS

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The official record still documents a draft consultation and ministerial answer, not an enacted implementation act. No new employer commencement date was confirmed.
Recommended next step
Maintain readiness and watch Folketing and Lovtidende for a bill and final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: DK-FT-CONSULTATION

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The government-approved ministry proposal still indicates a proposed 100+ reporting threshold, but enactment and a binding commencement date were not confirmed.
Recommended next step
Model the 100+ scenario for planning while keeping all dates conditional until the final act is published.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The current Labour Code equal-pay baseline was re-read. No accessible official source reviewed today confirmed a final national measure implementing Directive 2023/970.
Recommended next step
Keep the existing equal-pay baseline in force and obtain a current Hungarian legislative confirmation before asserting new Directive duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
Law 60/2018 remains the active verified equal-pay layer, including transparent remuneration-policy, evaluation/response and sanction mechanisms. No final Directive 2023/970 act was confirmed.
Recommended next step
Keep Law 60/2018 controls operational and track the separate Directive proposal to final publication.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The official Gender Pay Gap portal was inaccessible with HTTP 403 today. Existing 50+ reporting remains governed, but no later enacted Directive measure was confirmed from accessible official sources.
Recommended next step
Continue the existing 50+ reporting process and obtain direct official confirmation before changing the Directive implementation status.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: IE-GPG-PORTAL · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate record was re-read on 27 September. L445/2026 remains in permanent committees. The 60-day tacit-adoption period ends on 17 October 2026; this is a parliamentary milestone and does not activate an employer duty.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the revised 17 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
Consultation 12386 is closed and has a response summary, but the official record still does not show a final enacted act or binding employer start date.
Recommended next step
Track the official gazette and legislative file; keep implementation dates conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: BG-STRATEGY-CONSULTATION-12386

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The ministry states that Labour Act alignment is in progress and the published job-evaluation methodology is voluntary. No enacted Directive alignment was confirmed.
Recommended next step
Use the methodology as readiness guidance only and monitor the final Labour Act amendments.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: HR-MROSP-JOB-EVALUATION

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaRechecked
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
Project 26-TA-700 remains a draft law in the official TAP system. Consultation deadlines have passed, but no enacted act is shown.
Recommended next step
Track the project through Cabinet and Saeima stages; do not operationalise draft dates as binding.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: LV-TAP-26-TA-700

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The consultation is complete and revised bill/result documents are published, but the official page does not show enactment or confirmed commencement.
Recommended next step
Review the revised bill for planning and wait for the enacted law and commencement notice before asserting duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgOpen verification
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The official committee record documents discussion and a request concerning the Directive. No implementing bill, enacted act or employer threshold was confirmed in accessible official records today.
Recommended next step
Keep the EU baseline for readiness and obtain an official Luxembourg legislative file before asserting national duties.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recheck the named official source on 28 September 2026 or earlier if a final act is published.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The official 2026 Employment Equity portal and Department guidance were re-read on 27 September. EEA2 and EEA4 reporting remains open for designated employers. Manual and posted reports are not accepted after 1 October 2026; online submission remains open until 15 January 2027 at 23:59. CEO or accounting-officer approval and the acknowledgement package remain required evidence. No superseding rule was confirmed.
Recommended next step
If filing manually, complete consultation, CEO or accounting-officer approval, final reconciliation and dispatch now. Otherwise use the online route, validate EEA2/EEA4, press submit and retain the acknowledgement letter and submitted forms.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual or posted filing: 1 October 2026. Online filing: 15 January 2027 at 23:59.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 27 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

No superseding enacted pay-transparency change was confirmed on 26 September. The operational positions and deadlines remain in force as published; the most important near-term control remains Spain’s RD 723/2026 written-information workflow for 5 October. Finland HE 129/2026 and France bill 944 remain pending, while Romania L445/2026 remains in Senate committees with a 17 October parliamentary milestone rather than an employer deadline.

0 Changed0 Practical detail39 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline were covered by the 26 September differential review. The read-only monitor attempted all 109 governed primary-source routes: 92 were reachable and 18 warning signals were recorded across restricted, redirected, HTTP-error or network-error outcomes. Availability is not a legal conclusion. Current official content was re-read for the EU baseline and the moving Finland, France, Romania and Spain files; no enacted change superseding the published employer controls was confirmed. The remaining records retain their last substantive legal-review dates; a link check did not advance them.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
Finlex and the official government project record were re-read on 26 September. HE 129/2026 remains a proposal delivered to Parliament on 9 July 2026; the government project still shows the matter in progress with a timetable through 1 January 2027. No adopted act or enacted commencement was confirmed.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 26 September. Bill no. 944 still shows only its 10 September deposit and first reading under the accelerated procedure; the dossier was last updated on 18 September and shows no adopted act or commencement.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The government answer reported on 16 July 2026 describes preparatory transposition work. A Die Linke motion reported on 9 September calls for legislation; it is an opposition motion, not a government bill or enacted act. The cited review does not verify comprehensive enacted transposition.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified
Finding
BOE was re-read on 26 September. No superseding act was confirmed. RD 902/2020 remains the binding equal-pay, remuneration-register, equal-value and applicable pay-audit layer. RD 723/2026 remains scheduled to take effect on 5 October 2026 as a separate written-employment-information layer that partially transposes Directive (EU) 2019/1152, not Directive (EU) 2023/970; Spain’s EU Pay Transparency completeness status therefore remains unverified.
Recommended next step
Maintain the RD 902/2020 remuneration register and applicable equality-plan pay audit; consult legal worker representatives at least ten days before creating or changing the register and retain the consultation evidence; confirm collective-agreement and autonomous-community effects locally. In parallel, map each RD 723/2026 item to the offer/contract information pack, payroll dictionary and delivery log, and test pre-start delivery, same-day change notices and the algorithmic-pay explanation.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
Operational by 5 October 2026. New-hire information before employment starts; changes no later than the day they take effect. Existing workers may request missing information under the transitional rule.

Evidence: ES-RD902-CONSOLIDATED · ES-RD723 · EU-PTD

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The Dutch government page states that both parliamentary chambers still need to approve Bill 36949. The planned 1 January 2027 start remains conditional on that legislative process and is not a confirmed enacted effective date.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The government's no-bill and renegotiation announcement was on 26 March 2026. The 8 June announcement concerned resumed preparation and promotional work through the Equality Ombudsman. Guidance updated on 17 June said legislation was incomplete. These dated records do not establish an exhaustive September legislative status.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The ministerial answer dated 27 August 2026 describes proposed reporting for certain employers with 50–99 workers where the same function includes at least eight men and eight women. This is not blanket coverage of every employer with 50+ workers, and enactment is not established by the answer.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The Ministry of Labour page, updated on 31 August 2026, confirms government approval of the transposition proposal. The proposal is a substantive legislative step, but government approval does not establish enacted law or a general effective date.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The official Labour Code text inspected on 13 September 2026 retains section 12 on equal treatment in remuneration and assessment of equal-value work; the displayed consolidation is dated 28 February 2025. This review does not verify September transposition. The autumn programme remained inaccessible behind CAPTCHA. The separate 11 September EUR-Lex observation of zero notified Hungarian measures is unchanged and does not prove that domestic legislation or proposals are absent.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: BTE Separata 26/2026 of 5 August contains an official partial-transposition draft whose 20-day consultation period has elapsed. It proposes pre-contract pay information, a salary-history ban, information rights and reporting for employers with 50+ workers. Existing Law 60/2018 remains separate from these proposals.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Existing Irish gender-pay-gap reporting remains separate from full Directive transposition. In the official 16 June 2026 answer, the Minister confirmed delayed full transposition and continuing annual publication; central-portal filing was described as following an amendment. The 13 September review read that answer, the consolidation dated 31 May 2025 and the original draft Heads 4 and 5. September enactment and mandatory portal commencement remain unverified.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence: IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026 · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate record was re-read on 26 September. L445/2026 remains in permanent committees. The 60-day tacit-adoption period ends on 17 October 2026; this is a parliamentary milestone and does not activate an employer duty.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the revised 17 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Official consultation 12386 ran from 19 May to 18 June 2026 and is inactive. Results are dated 11 August; the final Council of Ministers act field was blank in the reviewed record. This supports a completion-proposal update, not a claim of enacted comprehensive transposition.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The ministry provides job-evaluation models for small, medium and large enterprises, including guidance dated 9 September 2026. The models assess the job rather than the person. Labour Act alignment is described as in progress; preparatory guidance is not evidence that transposition is already in force.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The TAP record documents consultation from 26 March to 9 April, coordination from 27 June to 10 July and opinions on 14 July 2026. The reviewed draft is a planning input; its thresholds and reporting dates are not presented as binding employer duties.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The official consultation was published on 5 November 2025 and closed on 4 December 2025. Results and a revised bill are available. Article 36 proposes commencement on future Gazette publication; this clause does not establish that publication or commencement has occurred.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The Chamber of Deputies records Labour Committee discussion on 24 June 2026. The cited review does not verify comprehensive enacted transposition, but the committee record means a categorical pre-draft or no-bill description is not justified. The review is not an exhaustive search for later legislation.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The live Department portal confirms the 2026 EEA2/EEA4 cycle is open. Listed designated employers include those with 50+ employees, organs of state and employers with 1–49 employees designated by collective agreement. This is a fresh operational review; the 2025 regulations were not reread successfully in this pass.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 26 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

Spain follow-up correction: Royal Decree 723/2026 is enacted and takes effect on 5 October 2026 as a complementary written-employment-information layer. It partially transposes Directive (EU) 2019/1152, not Directive (EU) 2023/970; Spain's EU Pay Transparency completeness status remains unchanged. No superseding enacted change was confirmed for the other tracked jurisdictions.

1 Changed0 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline remain covered. The scheduled 108-source pass completed earlier on 25 September; this same-day follow-up correction added a 109th governed source after an article-level read of BOE Royal Decrees 902/2020 and 723/2026 and a classification check against Directive (EU) 2023/970. Spain's legal-review date advanced for that substantive review. Availability checks and notification counts remain separate from legal conclusions.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
Finlex and the official government project record were re-read on 25 September. HE 129/2026 remains a proposal delivered to Parliament on 9 July 2026. The project timetable runs to 1 January 2027, but no adopted act or enacted commencement was confirmed.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 25 September. Bill no. 944 remains at first reading after its 10 September deposit under the accelerated procedure; no adopted act or commencement is shown.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The government answer reported on 16 July 2026 describes preparatory transposition work. A Die Linke motion reported on 9 September calls for legislation; it is an opposition motion, not a government bill or enacted act. The cited review does not verify comprehensive enacted transposition.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainLegal change
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
BOE confirms two separate layers. Royal Decree 902/2020 has applied since 14 April 2021 for equal pay, remuneration registers, equal-value controls and applicable pay audits. Royal Decree 723/2026 was published on 15 September and takes effect on 5 October 2026. Articles 3 and 7 require written information before employment starts on base salary, each supplement separately, payment frequency and method, variable-pay calculation and criteria, overtime remuneration, and algorithmic systems affecting pay; later changes are due no later than their effective day. RD 723/2026 partially transposes Directive (EU) 2019/1152, not Directive (EU) 2023/970, so the EU Pay Transparency completeness status is unchanged.
Recommended next step
Maintain the RD 902/2020 remuneration register and applicable equality-plan pay audit; consult legal worker representatives at least ten days before creating or changing the register and retain the consultation evidence; confirm collective-agreement and autonomous-community effects locally. In parallel, map each RD 723/2026 item to the offer/contract information pack, payroll dictionary and delivery log, and test pre-start delivery, same-day change notices and the algorithmic-pay explanation.
Suggested owner
HR and payroll lead with Spanish employment counsel and the owner of automated decision systems
Timing / condition
Operational by 5 October 2026. New-hire information before employment starts; changes no later than the day they take effect. Existing workers may request missing information under the transitional rule.
Effective date / applicability
2026-10-05 — Royal Decree 723/2026 enters into force twenty days after BOE publication.

Evidence: ES-RD902-CONSOLIDATED · ES-RD723 · EU-PTD

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The Dutch government page states that both parliamentary chambers still need to approve Bill 36949. The planned 1 January 2027 start remains conditional on that legislative process and is not a confirmed enacted effective date.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The government's no-bill and renegotiation announcement was on 26 March 2026. The 8 June announcement concerned resumed preparation and promotional work through the Equality Ombudsman. Guidance updated on 17 June said legislation was incomplete. These dated records do not establish an exhaustive September legislative status.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The ministerial answer dated 27 August 2026 describes proposed reporting for certain employers with 50–99 workers where the same function includes at least eight men and eight women. This is not blanket coverage of every employer with 50+ workers, and enactment is not established by the answer.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The Ministry of Labour page, updated on 31 August 2026, confirms government approval of the transposition proposal. The proposal is a substantive legislative step, but government approval does not establish enacted law or a general effective date.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The official Labour Code text inspected on 13 September 2026 retains section 12 on equal treatment in remuneration and assessment of equal-value work; the displayed consolidation is dated 28 February 2025. This review does not verify September transposition. The autumn programme remained inaccessible behind CAPTCHA. The separate 11 September EUR-Lex observation of zero notified Hungarian measures is unchanged and does not prove that domestic legislation or proposals are absent.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: BTE Separata 26/2026 of 5 August contains an official partial-transposition draft whose 20-day consultation period has elapsed. It proposes pre-contract pay information, a salary-history ban, information rights and reporting for employers with 50+ workers. Existing Law 60/2018 remains separate from these proposals.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Existing Irish gender-pay-gap reporting remains separate from full Directive transposition. In the official 16 June 2026 answer, the Minister confirmed delayed full transposition and continuing annual publication; central-portal filing was described as following an amendment. The 13 September review read that answer, the consolidation dated 31 May 2025 and the original draft Heads 4 and 5. September enactment and mandatory portal commencement remain unverified.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence: IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026 · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate record was re-read on 25 September. L445/2026 remains in permanent committees; the latest listed procedure is still the 21 September extension to a 60-day tacit-adoption period ending 17 October. The date is not an employer deadline.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the revised 17 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Official consultation 12386 ran from 19 May to 18 June 2026 and is inactive. Results are dated 11 August; the final Council of Ministers act field was blank in the reviewed record. This supports a completion-proposal update, not a claim of enacted comprehensive transposition.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The ministry provides job-evaluation models for small, medium and large enterprises, including guidance dated 9 September 2026. The models assess the job rather than the person. Labour Act alignment is described as in progress; preparatory guidance is not evidence that transposition is already in force.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The TAP record documents consultation from 26 March to 9 April, coordination from 27 June to 10 July and opinions on 14 July 2026. The reviewed draft is a planning input; its thresholds and reporting dates are not presented as binding employer duties.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The official consultation was published on 5 November 2025 and closed on 4 December 2025. Results and a revised bill are available. Article 36 proposes commencement on future Gazette publication; this clause does not establish that publication or commencement has occurred.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The Chamber of Deputies records Labour Committee discussion on 24 June 2026. The cited review does not verify comprehensive enacted transposition, but the committee record means a categorical pre-draft or no-bill description is not justified. The review is not an exhaustive search for later legislation.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The live Department portal confirms the 2026 EEA2/EEA4 cycle is open. Listed designated employers include those with 50+ employees, organs of state and employers with 1–49 employees designated by collective agreement. This is a fresh operational review; the 2025 regulations were not reread successfully in this pass.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 25 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

No newly enacted pay-transparency change was confirmed. Romania L445/2026 remains in Senate committees after the 21 September timetable extension, France bill no. 944 remains at first reading, and Poland UC127 remains a government bill project with Q4 2026 adoption planned.

0 Changed0 Practical detail39 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline were compared with production commit 7b1663c1 through the governed 108-source register. The automated pass produced 17 access, redirect or network warnings and no critical legal finding; availability signals did not change legal claims. Content review re-read the official Romania Senate, France Senate and Poland government-register records. Legal-review dates advanced only for those three content reviews; all other legal-review dates remain separate from the 24 September access check.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The ministry published a voluntary gender-neutral job-evaluation model on 3 September 2026. Incomes Register guidance updated on 8 September sets out reporting preparations under HE 129/2026. The bill remains before Parliament; 1 January 2027 is proposed commencement, not enacted law.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT · FI-INCOMES-REGISTER

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The official Senate dossier was re-read on 24 September. Bill no. 944 remains at first reading after its 10 September deposit under the accelerated procedure; no adopted act or commencement is shown.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The government answer reported on 16 July 2026 describes preparatory transposition work. A Die Linke motion reported on 9 September calls for legislation; it is an opposition motion, not a government bill or enacted act. The cited review does not verify comprehensive enacted transposition.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
The official government register was re-read on 24 September. UC127 remains an EU-implementing bill project; the status field is blank and Council of Ministers adoption is still planned for Q4 2026. This is not enacted law.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127

Open country brief →
SpainRechecked
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The consolidated Royal Decree 902/2020 requires a pay register for all companies, including management and senior executives. Registers include sex-disaggregated means and medians; pay audits form part of equality plans. A prior Directive consultation ran from 24 April to 8 May 2026 and is closed; that historical consultation does not prove there was no later legislation.
Recommended next step
Add a consultation checkpoint before payroll signs off a register change; retain the invitation, consultation record and final register.
Suggested owner
HR and payroll lead
Timing / condition
At least ten days before the register is created or modified.

Evidence: ES-RD902-CONSOLIDATED

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The Dutch government page states that both parliamentary chambers still need to approve Bill 36949. The planned 1 January 2027 start remains conditional on that legislative process and is not a confirmed enacted effective date.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The government's no-bill and renegotiation announcement was on 26 March 2026. The 8 June announcement concerned resumed preparation and promotional work through the Equality Ombudsman. Guidance updated on 17 June said legislation was incomplete. These dated records do not establish an exhaustive September legislative status.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The ministerial answer dated 27 August 2026 describes proposed reporting for certain employers with 50–99 workers where the same function includes at least eight men and eight women. This is not blanket coverage of every employer with 50+ workers, and enactment is not established by the answer.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The Ministry of Labour page, updated on 31 August 2026, confirms government approval of the transposition proposal. The proposal is a substantive legislative step, but government approval does not establish enacted law or a general effective date.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The official Labour Code text inspected on 13 September 2026 retains section 12 on equal treatment in remuneration and assessment of equal-value work; the displayed consolidation is dated 28 February 2025. This review does not verify September transposition. The autumn programme remained inaccessible behind CAPTCHA. The separate 11 September EUR-Lex observation of zero notified Hungarian measures is unchanged and does not prove that domestic legislation or proposals are absent.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: BTE Separata 26/2026 of 5 August contains an official partial-transposition draft whose 20-day consultation period has elapsed. It proposes pre-contract pay information, a salary-history ban, information rights and reporting for employers with 50+ workers. Existing Law 60/2018 remains separate from these proposals.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Existing Irish gender-pay-gap reporting remains separate from full Directive transposition. In the official 16 June 2026 answer, the Minister confirmed delayed full transposition and continuing annual publication; central-portal filing was described as following an amendment. The 13 September review read that answer, the consolidation dated 31 May 2025 and the original draft Heads 4 and 5. September enactment and mandatory portal commencement remain unverified.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence: IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026 · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The official Senate record was re-read on 24 September. L445/2026 remains in permanent committees; no later procedure entry appears after the 21 September extension to a 60-day tacit-adoption period ending 17 October. The date is not an employer deadline.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the revised 17 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Official consultation 12386 ran from 19 May to 18 June 2026 and is inactive. Results are dated 11 August; the final Council of Ministers act field was blank in the reviewed record. This supports a completion-proposal update, not a claim of enacted comprehensive transposition.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The ministry provides job-evaluation models for small, medium and large enterprises, including guidance dated 9 September 2026. The models assess the job rather than the person. Labour Act alignment is described as in progress; preparatory guidance is not evidence that transposition is already in force.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The TAP record documents consultation from 26 March to 9 April, coordination from 27 June to 10 July and opinions on 14 July 2026. The reviewed draft is a planning input; its thresholds and reporting dates are not presented as binding employer duties.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The official consultation was published on 5 November 2025 and closed on 4 December 2025. Results and a revised bill are available. Article 36 proposes commencement on future Gazette publication; this clause does not establish that publication or commencement has occurred.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The Chamber of Deputies records Labour Committee discussion on 24 June 2026. The cited review does not verify comprehensive enacted transposition, but the committee record means a categorical pre-draft or no-bill description is not justified. The review is not an exhaustive search for later legislation.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The live Department portal confirms the 2026 EEA2/EEA4 cycle is open. Listed designated employers include those with 50+ employees, organs of state and employers with 1–49 employees designated by collective agreement. This is a fresh operational review; the 2025 regulations were not reread successfully in this pass.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 24 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

No legal-content change is asserted for 23 September. The governed 108-source availability monitor completed with 11 warnings, no error and no critical finding; the exact prior production positions remain in force pending source-content review.

0 Changed0 Practical detail0 Rechecked45 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline were compared with production commit 7b1663c1. The read-only monitor attempted all 108 governed sources and reported restricted access for Lithuania, Denmark, Greece, India and the France Cabinet source, one redirected Poland source, and one Brazil network error. These availability signals do not establish a legal change. Legal-review dates were not advanced.

European UnionOpen verification
Previously
EU baseline in force; national law must be checked
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence:

Open country brief →
SlovakiaOpen verification
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence:

Open country brief →
ItalyOpen verification
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence:

Open country brief →
LithuaniaOpen verification
Previously
National amendments in force with staged operational dates
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence:

Open country brief →
FinlandOpen verification
Previously
Government bill pending — not enacted law
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence:

Open country brief →
FranceOpen verification
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence:

Open country brief →
GermanyOpen verification
Previously
Preparatory government work and opposition motion documented
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence:

Open country brief →
PolandOpen verification
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence:

Open country brief →
SpainOpen verification
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Add a consultation checkpoint before payroll signs off a register change; retain the invitation, consultation record and final register.
Suggested owner
HR and payroll lead
Timing / condition
At least ten days before the register is created or modified.

Evidence:

Open country brief →
NetherlandsOpen verification
Previously
Government bill awaits both chambers; start date conditional
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence:

Open country brief →
BelgiumOpen verification
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence:

Open country brief →
SwedenOpen verification
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence:

Open country brief →
DenmarkOpen verification
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence:

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence:

Open country brief →
CzechiaOpen verification
Previously
Government-approved transposition proposal; enactment not verified
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence:

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence:

Open country brief →
PortugalOpen verification
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence:

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence:

Open country brief →
RomaniaOpen verification
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the revised 17 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence:

Open country brief →
BulgariaOpen verification
Previously
Consultation closed; final enactment not established by the record
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence:

Open country brief →
CroatiaOpen verification
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence:

Open country brief →
SloveniaOpen verification
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence:

Open country brief →
EstoniaOpen verification
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence:

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence:

Open country brief →
GreeceOpen verification
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence:

Open country brief →
CyprusOpen verification
Previously
Consultation closed; revised bill available
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence:

Open country brief →
MaltaOpen verification
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence:

Open country brief →
LuxembourgOpen verification
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence:

Open country brief →
United KingdomOpen verification
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence:

Open country brief →
United StatesOpen verification
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence:

Open country brief →
AustraliaOpen verification
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence:

Open country brief →
CanadaOpen verification
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence:

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence:

Open country brief →
JapanOpen verification
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence:

Open country brief →
South KoreaOpen verification
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence:

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence:

Open country brief →
South AfricaOpen verification
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence:

Open country brief →
IndiaOpen verification
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence:

Open country brief →
SingaporeOpen verification
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence:

Open country brief →
SwitzerlandOpen verification
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence:

Open country brief →
IcelandOpen verification
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence:

Open country brief →
New ZealandOpen verification
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence:

Open country brief →
PeruOpen verification
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence:

Open country brief →
ChileOpen verification
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence:

Open country brief →
ArgentinaOpen verification
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
The 23 September read-only source-access monitor did not perform a legal-content review. It found no error or critical condition, while availability warnings remain disclosed in the coverage note. The exact prior production position is retained and no new employer duty, threshold, deadline or legal status is asserted.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence:

Open country brief →

No newly enacted pay-transparency change was confirmed. Romania’s Senate record now exposes a favourable budget-committee opinion dated 15 September, while L445/2026 remains pending in permanent committees; France bill no. 944 remains pending first reading and Poland UC127 remains a government draft project.

1 Changed0 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline were compared with production commit 12dd67ef through the governed 108-source register. The automated pass flagged 18 access or redirect warnings, one 404 error, and no critical finding; availability signals did not change legal claims. Content review re-read the official France Senate and Romania Senate records. Legal-review dates advanced only for those two content reviews; all other legal-review dates remain separate from the 22 September access check.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The ministry published a voluntary gender-neutral job-evaluation model on 3 September 2026. Incomes Register guidance updated on 8 September sets out reporting preparations under HE 129/2026. The bill remains before Parliament; 1 January 2027 is proposed commencement, not enacted law.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT · FI-INCOMES-REGISTER

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: France has an existing professional-equality index. Government bill no. 944, intended to transpose Directive (EU) 2023/970, was deposited in the Senate on 10 September 2026 and placed under the accelerated procedure. First reading remains pending, so the bill does not yet create new employer duties.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The government answer reported on 16 July 2026 describes preparatory transposition work. A Die Linke motion reported on 9 September calls for legislation; it is an opposition motion, not a government bill or enacted act. The cited review does not verify comprehensive enacted transposition.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127 · PL-PIP-RECRUITMENT-CURRENT

Open country brief →
SpainRechecked
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The consolidated Royal Decree 902/2020 requires a pay register for all companies, including management and senior executives. Registers include sex-disaggregated means and medians; pay audits form part of equality plans. A prior Directive consultation ran from 24 April to 8 May 2026 and is closed; that historical consultation does not prove there was no later legislation.
Recommended next step
Add a consultation checkpoint before payroll signs off a register change; retain the invitation, consultation record and final register.
Suggested owner
HR and payroll lead
Timing / condition
At least ten days before the register is created or modified.

Evidence: ES-RD902-CONSOLIDATED

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The Dutch government page states that both parliamentary chambers still need to approve Bill 36949. The planned 1 January 2027 start remains conditional on that legislative process and is not a confirmed enacted effective date.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The government's no-bill and renegotiation announcement was on 26 March 2026. The 8 June announcement concerned resumed preparation and promotional work through the Equality Ombudsman. Guidance updated on 17 June said legislation was incomplete. These dated records do not establish an exhaustive September legislative status.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The ministerial answer dated 27 August 2026 describes proposed reporting for certain employers with 50–99 workers where the same function includes at least eight men and eight women. This is not blanket coverage of every employer with 50+ workers, and enactment is not established by the answer.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The Ministry of Labour page, updated on 31 August 2026, confirms government approval of the transposition proposal. The proposal is a substantive legislative step, but government approval does not establish enacted law or a general effective date.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The official Labour Code text inspected on 13 September 2026 retains section 12 on equal treatment in remuneration and assessment of equal-value work; the displayed consolidation is dated 28 February 2025. This review does not verify September transposition. The autumn programme remained inaccessible behind CAPTCHA. The separate 11 September EUR-Lex observation of zero notified Hungarian measures is unchanged and does not prove that domestic legislation or proposals are absent.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: BTE Separata 26/2026 of 5 August contains an official partial-transposition draft whose 20-day consultation period has elapsed. It proposes pre-contract pay information, a salary-history ban, information rights and reporting for employers with 50+ workers. Existing Law 60/2018 remains separate from these proposals.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Existing Irish gender-pay-gap reporting remains separate from full Directive transposition. In the official 16 June 2026 answer, the Minister confirmed delayed full transposition and continuing annual publication; central-portal filing was described as following an amendment. The 13 September review read that answer, the consolidation dated 31 May 2025 and the original draft Heads 4 and 5. September enactment and mandatory portal commencement remain unverified.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence: IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026 · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaChanged
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The Senate record now lists a 60-day tacit-adoption period ending 17 October 2026, replacing the previously displayed 2 October date. L445/2026 still remains in permanent committees. This is a parliamentary milestone, not an employer compliance date or enacted transposition.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the revised 17 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Official consultation 12386 ran from 19 May to 18 June 2026 and is inactive. Results are dated 11 August; the final Council of Ministers act field was blank in the reviewed record. This supports a completion-proposal update, not a claim of enacted comprehensive transposition.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The ministry provides job-evaluation models for small, medium and large enterprises, including guidance dated 9 September 2026. The models assess the job rather than the person. Labour Act alignment is described as in progress; preparatory guidance is not evidence that transposition is already in force.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The TAP record documents consultation from 26 March to 9 April, coordination from 27 June to 10 July and opinions on 14 July 2026. The reviewed draft is a planning input; its thresholds and reporting dates are not presented as binding employer duties.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The official consultation was published on 5 November 2025 and closed on 4 December 2025. Results and a revised bill are available. Article 36 proposes commencement on future Gazette publication; this clause does not establish that publication or commencement has occurred.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The Chamber of Deputies records Labour Committee discussion on 24 June 2026. The cited review does not verify comprehensive enacted transposition, but the committee record means a categorical pre-draft or no-bill description is not justified. The review is not an exhaustive search for later legislation.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The live Department portal confirms the 2026 EEA2/EEA4 cycle is open. Listed designated employers include those with 50+ employees, organs of state and employers with 1–49 employees designated by collective agreement. This is a fresh operational review; the 2025 regulations were not reread successfully in this pass.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 22 September differential review. Retained governed position: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

No newly enacted pay-transparency change was confirmed. Romania’s Senate record now exposes a favourable budget-committee opinion dated 15 September, while L445/2026 remains pending in permanent committees; France bill no. 944 remains pending first reading and Poland UC127 remains a government draft project.

1 Changed0 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline were compared with production commit 1dcf77b9 through the governed 108-source register. The automated pass flagged 23 access or redirect warnings and no critical or error finding; availability signals did not change legal claims. Content review re-read the official France Senate, Romania Senate and Poland government-register records. Legal-review dates advanced only for those three content reviews; all other legal-review dates remain separate from the 21 September access check.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The ministry published a voluntary gender-neutral job-evaluation model on 3 September 2026. Incomes Register guidance updated on 8 September sets out reporting preparations under HE 129/2026. The bill remains before Parliament; 1 January 2027 is proposed commencement, not enacted law.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT · FI-INCOMES-REGISTER

Open country brief →
FranceRechecked
Previously
Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: France has an existing professional-equality index. Government bill no. 944, intended to transpose Directive (EU) 2023/970, was deposited in the Senate on 10 September 2026 and placed under the accelerated procedure. First reading remains pending, so the bill does not yet create new employer duties.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The government answer reported on 16 July 2026 describes preparatory transposition work. A Die Linke motion reported on 9 September calls for legislation; it is an opposition motion, not a government bill or enacted act. The cited review does not verify comprehensive enacted transposition.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127 · PL-PIP-RECRUITMENT-CURRENT

Open country brief →
SpainRechecked
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The consolidated Royal Decree 902/2020 requires a pay register for all companies, including management and senior executives. Registers include sex-disaggregated means and medians; pay audits form part of equality plans. A prior Directive consultation ran from 24 April to 8 May 2026 and is closed; that historical consultation does not prove there was no later legislation.
Recommended next step
Add a consultation checkpoint before payroll signs off a register change; retain the invitation, consultation record and final register.
Suggested owner
HR and payroll lead
Timing / condition
At least ten days before the register is created or modified.

Evidence: ES-RD902-CONSOLIDATED

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The Dutch government page states that both parliamentary chambers still need to approve Bill 36949. The planned 1 January 2027 start remains conditional on that legislative process and is not a confirmed enacted effective date.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The government's no-bill and renegotiation announcement was on 26 March 2026. The 8 June announcement concerned resumed preparation and promotional work through the Equality Ombudsman. Guidance updated on 17 June said legislation was incomplete. These dated records do not establish an exhaustive September legislative status.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The ministerial answer dated 27 August 2026 describes proposed reporting for certain employers with 50–99 workers where the same function includes at least eight men and eight women. This is not blanket coverage of every employer with 50+ workers, and enactment is not established by the answer.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The Ministry of Labour page, updated on 31 August 2026, confirms government approval of the transposition proposal. The proposal is a substantive legislative step, but government approval does not establish enacted law or a general effective date.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The official Labour Code text inspected on 13 September 2026 retains section 12 on equal treatment in remuneration and assessment of equal-value work; the displayed consolidation is dated 28 February 2025. This review does not verify September transposition. The autumn programme remained inaccessible behind CAPTCHA. The separate 11 September EUR-Lex observation of zero notified Hungarian measures is unchanged and does not prove that domestic legislation or proposals are absent.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: BTE Separata 26/2026 of 5 August contains an official partial-transposition draft whose 20-day consultation period has elapsed. It proposes pre-contract pay information, a salary-history ban, information rights and reporting for employers with 50+ workers. Existing Law 60/2018 remains separate from these proposals.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Existing Irish gender-pay-gap reporting remains separate from full Directive transposition. In the official 16 June 2026 answer, the Minister confirmed delayed full transposition and continuing annual publication; central-portal filing was described as following an amendment. The 13 September review read that answer, the consolidation dated 31 May 2025 and the original draft Heads 4 and 5. September enactment and mandatory portal commencement remain unverified.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence: IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026 · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaChanged
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The Senate record for urgent proposal L445/2026 now lists a favourable budget-committee opinion issued on 15 September. The proposal remains in permanent committees, and the 2 October tacit-adoption date is a parliamentary milestone rather than an employer deadline or proof of enactment.
Recommended next step
Keep L445/2026 in the draft register, prepare the data model, and wait for final enactment and commencement before activating new thresholds or deadlines.
Suggested owner
Romania HR lead with local employment counsel
Timing / condition
Monitor the 2 October 2026 parliamentary milestone; no new employer deadline is confirmed.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Official consultation 12386 ran from 19 May to 18 June 2026 and is inactive. Results are dated 11 August; the final Council of Ministers act field was blank in the reviewed record. This supports a completion-proposal update, not a claim of enacted comprehensive transposition.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The ministry provides job-evaluation models for small, medium and large enterprises, including guidance dated 9 September 2026. The models assess the job rather than the person. Labour Act alignment is described as in progress; preparatory guidance is not evidence that transposition is already in force.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The TAP record documents consultation from 26 March to 9 April, coordination from 27 June to 10 July and opinions on 14 July 2026. The reviewed draft is a planning input; its thresholds and reporting dates are not presented as binding employer duties.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The official consultation was published on 5 November 2025 and closed on 4 December 2025. Results and a revised bill are available. Article 36 proposes commencement on future Gazette publication; this clause does not establish that publication or commencement has occurred.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The Chamber of Deputies records Labour Committee discussion on 24 June 2026. The cited review does not verify comprehensive enacted transposition, but the committee record means a categorical pre-draft or no-bill description is not justified. The review is not an exhaustive search for later legislation.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The live Department portal confirms the 2026 EEA2/EEA4 cycle is open. Listed designated employers include those with 50+ employees, organs of state and employers with 1–49 employees designated by collective agreement. This is a fresh operational review; the 2025 regulations were not reread successfully in this pass.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. A pay-equity claim generally concerns work performed by a workforce that is at least 70% female and has been predominantly female for at least ten consecutive years. The employer acknowledges a claim within five working days and generally decides whether it is arguable within 60 working days.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in the 21 September differential review. Current governed position remains: The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

France’s government bill no. 944 is now verified in the Senate’s official legislative dossier: it was deposited on 10 September under the accelerated procedure and remains pending first reading. No other newly enacted pay-transparency change was confirmed in today’s differential review.

1 Changed1 Practical detail37 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline were carried through the governed 108-source register and compared with production commit 82d2a864. The automated access pass reached 85 sources and recorded 22 restricted, timed-out or certificate-limited sources plus one same-host redirect; those signals did not change legal claims. Content review confirmed the current French Senate dossier and retained the 19 September substantive findings elsewhere unless a stronger official source was available. Legal-review dates were not advanced after link-only checks.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The EU timetable remains the baseline. National commencement, scope and remedies must be checked separately; a notification count is not a completeness certificate.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Section 18 separates the first 2027 category-average information from the current right to own-pay information. The first 150+ report covers only 1 August–31 December 2026.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Decree 96/2026 is published and in force. Publication of the act does not establish that every article 9 implementing arrangement is operational.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The ministry distinguishes monthly Sodra data from the first annual gap reports in 2028. The 2028 annual report is not permission to defer payroll preparation until 2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandPractical detail
Previously
Government bill pending — not enacted law
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The official project remains at the 'submitted to Parliament' stage for HE 129/2026. The page also displays a generic later milestone labelled 'legislation approved'; that milestone label is not evidence that the bill has been enacted.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT · FI-INCOMES-REGISTER

Open country brief →
FranceChanged
Previously
Bill presented to Cabinet; enactment not verified
Finding
The official Senate dossier now verifies government bill no. 944, deposited on 10 September 2026 under the accelerated procedure. First reading is pending; this is a proposal, not enacted law.
Recommended next step
Keep the existing equality-index workflow active. Map payroll, equal-value categories and recruitment fields to the proposal, but activate new duties only after final enactment and decree review.
Suggested owner
HR lead with French employment counsel
Timing / condition
Monitor Senate first reading and amendments now; no bill-based employer deadline applies before enactment.

Evidence: FR-SENATE-PJL944

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The Bundestag’s 9 September item concerns opposition motion 21/7916 requesting legislation. It creates no employer duty.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: UC127 still records planned Cabinet adoption in Q4 2026. Existing recruitment-pay information must continue independently of this wider draft.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127 · PL-PIP-RECRUITMENT-CURRENT

Open country brief →
SpainRechecked
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: RD 902/2020 article 5 requires consultation with worker representatives at least ten days before creating or changing the pay register. Register, equality-plan audit and the EU 5% condition are distinct.
Recommended next step
Add a consultation checkpoint before payroll signs off a register change; retain the invitation, consultation record and final register.
Suggested owner
HR and payroll lead
Timing / condition
At least ten days before the register is created or modified.

Evidence: ES-RD902-CONSOLIDATED

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Government guidance still makes the 1 January 2027 start conditional on parliamentary approval. This review does not establish a final act.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The Equality Ombudsman still distinguishes preparatory work from finished legislation. Existing pay-survey duties are not suspended by the EU implementation debate.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The parliamentary question and answer describe proposed reporting, including a conditional 50–99-worker category. They are not an enacted filing instruction.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Section 11a confirms a biennial anonymised income report and first-quarter delivery. Official guidance and the statutory-search wording disagree at exactly 150 workers; the current section 63 could not be fully retrieved.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The 31 August ministry announcement records a government-approved proposal. Its 2028/2031 reporting timetable still needs the final parliamentary act.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The verified Labour Code baseline is retained. The autumn programme was blocked by CAPTCHA and the current full-transposition outcome remains unverified; the older zero-notification observation is not refreshed.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: BTE Separata 26/2026 expressly labels the text a proposal for public consultation and partial transposition. Its proposed 50–249 reporting bracket is not a current legal instruction.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The official administrative consolidation says the Employment Equality Act is current through 17 September 2026. The reviewed legislation programme and ministerial answer still do not identify an enacted Pay Transparency Directive transposition act.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence: IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026 · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The Senate record still lists L445/2026 as in work before the permanent committees. It remains a legislative proposal, not enacted employer law.
Recommended next step
Keep the gap analysis and equal-value category design in preparation status and trigger legal implementation only against an adopted and published act.
Suggested owner
HR lead with Romanian employment counsel
Timing / condition
Recheck after the next committee or plenary status change.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The official consultation export now provides an inspectable history: closed on 18 June and a response summary recorded on 11 August. No final Council act is listed in this export.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The ministry lists job-evaluation tools for small, medium and large employers and updated 9 September supporting files. Tools support preparation; they do not prove enacted transposition.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The ministry separates active recruitment changes from the wider paused package. Older implementation-plan paragraphs on the same page should not be read as current enacted reporting.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The retained TAP draft and proposed dates remain labelled as proposals. Today’s full draft retrieval failed, so a later adoption or revision could not be ruled out.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The parliamentary record confirms Law 5316 and Gazette 105 A/6 July 2026. This review of the record does not close the outstanding article-by-article commencement and implementing-decision check.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The official consultation is closed: published 5 November 2025, comments ended 4 December 2025. A bill titled “2026” is not by itself an enacted 2026 law.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Regulation 9 specifies the first reference periods explicitly: 2026 for 150+ and 2030 for 100–149. The separate fourteen-working-day wording still needs local operational clarification.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The Chamber record is a committee discussion requested by a political group. It cannot establish a transposition act or an employer commencement date.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The 250+ Great Britain reporting duty is mandatory. Gender-pay-gap action plans are currently voluntary; the stated spring-2027 mandatory start is subject to legislation.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: California requires an in-post pay scale for covered 15+ employers, including roles potentially filled remotely in California. Its 100+ pay-data reports are separate from federal EEO-1. This is not a complete state-by-state survey.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: WGEA reporting requires CEO sign-off and sharing specified reports. Directly employing relevant employers with 500+ workers also choose three gender-equality targets and have three years to meet them or demonstrate improvement.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The regulator’s page, modified 11 September, distinguishes federal 10+ proactive pay equity from other regimes. Plans are normally due within three years of becoming subject and updated at least every five years.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The official sixth-report notice confirms the 3–31 August information-update window for 100+ employers. Today’s review did not establish that the sixth report is already available for every employer.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: From April 2026, 101+ regular-worker employers disclose both the gender wage gap and the women-manager ratio. Additional required indicators depend on size; timing follows the employer’s financial year.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Correction: the old under-five-worker exception was deleted in 2018. Article 8 equal-value pay cannot be presented as starting only at five regular workers; the decree’s specific exceptions still need scope checking.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The retained 519+ and specified-entity framework remains the baseline. Current regulator instructions and any 2026 deadline extension were not successfully verified; the old early-June wording must not be treated as a confirmed current deadline.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The live 2026 portal accepts EEA2 and EEA4 only, not EEA12/13. It requires CEO approval and an acknowledgement of receipt; no amendment is allowed after final submission.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The official explanation explicitly includes transgender identity in section 3 gender-discrimination controls for wages and recruitment. A generic male/female-only policy misses that scope.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The MOM parliamentary reply targets Workplace Fairness Act implementation at the end of 2027. Present fair-employment expectations and the future Act’s commencement are separate.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The regulator links repeat analysis to the prior result: repetition every four years where equality was not met; an employer newly reaching 100 workers at the start of a year has its own first-analysis clock.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The national 50+ reporting transition depends on the latest certification/confirmation. Regulation 946/2026 also requires an approved equality plan before filing.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Current guidance uses a merit-and-requirements assessment, not the older arguability wording. Acknowledge within five working days; decide within 60 working days, with a reasoned limited extension where allowed.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Correction: the prior 4 August 2026 Supreme Court claim was not supported by the cited evidence and has been removed. Confirmed guidance requires job-category/function schedules and informing workers of salary policy.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: The official interpretation supports a reasoned written response within 30 days and the internal complaint/role-register controls. This is an existing same-work framework, not a newly verified universal public report.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
No superseding official act was confirmed in today’s differential review. Retained substantive finding from 19 September: Correction: Law 25,877 article 25 says more than 300 workers, not 300 or more. The annual social balance is confidential; union delivery is within 30 days after preparation, with a copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

No new enacted pay-transparency change was confirmed today. The review clarifies Finland's still-pending parliamentary stage, confirms Romania's committee status and separates Ireland's newly updated consolidated baseline from the still-unverified Directive transposition.

0 Changed1 Practical detail38 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline were reviewed against the 107-source governed register. A bounded content capture directly yielded readable official material for 69 sources; restricted, scripted or PDF-only sources were supplemented with official indexed records where available and unresolved access limits remain explicit. No legal conclusion was inferred from HTTP status or a notification count.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
The EU timetable remains the baseline. National commencement, scope and remedies must be checked separately; a notification count is not a completeness certificate.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
Section 18 separates the first 2027 category-average information from the current right to own-pay information. The first 150+ report covers only 1 August–31 December 2026.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
Decree 96/2026 is published and in force. Publication of the act does not establish that every article 9 implementing arrangement is operational.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
The ministry distinguishes monthly Sodra data from the first annual gap reports in 2028. The 2028 annual report is not permission to defer payroll preparation until 2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandPractical detail
Previously
Government bill pending — not enacted law
Finding
The official project remains at the 'submitted to Parliament' stage for HE 129/2026. The page also displays a generic later milestone labelled 'legislation approved'; that milestone label is not evidence that the bill has been enacted.
Recommended next step
Keep the payroll-field mapping as enactment-dependent preparation and monitor Parliament and Finlex for the adopted act and commencement text.
Suggested owner
HR lead with Finnish employment counsel
Timing / condition
Review immediately when Parliament adopts or amends HE 129/2026; the project timetable runs to 1 January 2027.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT · FI-INCOMES-REGISTER

Open country brief →
FranceRechecked
Previously
Bill presented to Cabinet; enactment not verified
Finding
The 10 September Cabinet text proposes retaining the existing private-sector index in 2027 and moving to the new framework in 2028. It is a bill, not enacted transition law.
Recommended next step
Keep the current index workflow funded and prepare a separate change plan; do not cancel existing reporting because a replacement has been announced.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue current index dates; proposed 2028 transition remains conditional.

Evidence: FR-CABINET-PTD-BILL

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
The Bundestag’s 9 September item concerns opposition motion 21/7916 requesting legislation. It creates no employer duty.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
UC127 still records planned Cabinet adoption in Q4 2026. Existing recruitment-pay information must continue independently of this wider draft.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127 · PL-PIP-RECRUITMENT-CURRENT

Open country brief →
SpainRechecked
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
RD 902/2020 article 5 requires consultation with worker representatives at least ten days before creating or changing the pay register. Register, equality-plan audit and the EU 5% condition are distinct.
Recommended next step
Add a consultation checkpoint before payroll signs off a register change; retain the invitation, consultation record and final register.
Suggested owner
HR and payroll lead
Timing / condition
At least ten days before the register is created or modified.

Evidence: ES-RD902-CONSOLIDATED

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
Government guidance still makes the 1 January 2027 start conditional on parliamentary approval. This review does not establish a final act.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumRechecked
Previously
Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed
Finding
Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
The Equality Ombudsman still distinguishes preparatory work from finished legislation. Existing pay-survey duties are not suspended by the EU implementation debate.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The parliamentary question and answer describe proposed reporting, including a conditional 50–99-worker category. They are not an enacted filing instruction.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
Section 11a confirms a biennial anonymised income report and first-quarter delivery. Official guidance and the statutory-search wording disagree at exactly 150 workers; the current section 63 could not be fully retrieved.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The 31 August ministry announcement records a government-approved proposal. Its 2028/2031 reporting timetable still needs the final parliamentary act.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The verified Labour Code baseline is retained. The autumn programme was blocked by CAPTCHA and the current full-transposition outcome remains unverified; the older zero-notification observation is not refreshed.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
BTE Separata 26/2026 expressly labels the text a proposal for public consultation and partial transposition. Its proposed 50–249 reporting bracket is not a current legal instruction.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The official administrative consolidation says the Employment Equality Act is current through 17 September 2026. The reviewed legislation programme and ministerial answer still do not identify an enacted Pay Transparency Directive transposition act.
Recommended next step
Continue the existing gender-pay-gap reporting workflow and keep Directive-specific recruitment, worker-request and equal-value changes in a controlled pending-law plan.
Suggested owner
HR lead with Irish employment counsel
Timing / condition
Monitor the Oireachtas and Irish Statute Book continuously; do not treat the updated consolidation date as transposition.

Evidence: IE-EMPLOYMENT-EQUALITY-CONSOLIDATION · IE-LEGISLATION-PROGRAMME-SUMMER-2026 · IE-PTD-MINISTER-20260616

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
The Senate record still lists L445/2026 as in work before the permanent committees. It remains a legislative proposal, not enacted employer law.
Recommended next step
Keep the gap analysis and equal-value category design in preparation status and trigger legal implementation only against an adopted and published act.
Suggested owner
HR lead with Romanian employment counsel
Timing / condition
Recheck after the next committee or plenary status change.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaRechecked
Previously
Consultation closed; final enactment not established by the record
Finding
The official consultation export now provides an inspectable history: closed on 18 June and a response summary recorded on 11 August. No final Council act is listed in this export.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The ministry lists job-evaluation tools for small, medium and large employers and updated 9 September supporting files. Tools support preparation; they do not prove enacted transposition.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaRechecked
Previously
Ministry plans transposition by end-2026; final enactment not verified
Finding
On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
The ministry separates active recruitment changes from the wider paused package. Older implementation-plan paragraphs on the same page should not be read as current enacted reporting.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
The retained TAP draft and proposed dates remain labelled as proposals. Today’s full draft retrieval failed, so a later adoption or revision could not be ruled out.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
The parliamentary record confirms Law 5316 and Gazette 105 A/6 July 2026. This review of the record does not close the outstanding article-by-article commencement and implementing-decision check.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The official consultation is closed: published 5 November 2025, comments ended 4 December 2025. A bill titled “2026” is not by itself an enacted 2026 law.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
Regulation 9 specifies the first reference periods explicitly: 2026 for 150+ and 2030 for 100–149. The separate fourteen-working-day wording still needs local operational clarification.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The Chamber record is a committee discussion requested by a political group. It cannot establish a transposition act or an employer commencement date.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomRechecked
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
The 250+ Great Britain reporting duty is mandatory. Gender-pay-gap action plans are currently voluntary; the stated spring-2027 mandatory start is subject to legislation.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesRechecked
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
California requires an in-post pay scale for covered 15+ employers, including roles potentially filled remotely in California. Its 100+ pay-data reports are separate from federal EEO-1. This is not a complete state-by-state survey.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaRechecked
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
WGEA reporting requires CEO sign-off and sharing specified reports. Directly employing relevant employers with 500+ workers also choose three gender-equality targets and have three years to meet them or demonstrate improvement.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaRechecked
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
The regulator’s page, modified 11 September, distinguishes federal 10+ proactive pay equity from other regimes. Plans are normally due within three years of becoming subject and updated at least every five years.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
The official sixth-report notice confirms the 3–31 August information-update window for 100+ employers. Today’s review did not establish that the sixth report is already available for every employer.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanRechecked
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
From April 2026, 101+ regular-worker employers disclose both the gender wage gap and the women-manager ratio. Additional required indicators depend on size; timing follows the employer’s financial year.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaRechecked
Previously
Equal-value pay applies under the Act; the old under-five-worker exemption was deleted
Finding
Correction: the old under-five-worker exception was deleted in 2018. Article 8 equal-value pay cannot be presented as starting only at five regular workers; the decree’s specific exceptions still need scope checking.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
The retained 519+ and specified-entity framework remains the baseline. Current regulator instructions and any 2026 deadline extension were not successfully verified; the old early-June wording must not be treated as a confirmed current deadline.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaRechecked
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The live 2026 portal accepts EEA2 and EEA4 only, not EEA12/13. It requires CEO approval and an acknowledgement of receipt; no amendment is allowed after final submission.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaRechecked
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
The official explanation explicitly includes transgender identity in section 3 gender-discrimination controls for wages and recruitment. A generic male/female-only policy misses that scope.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
The MOM parliamentary reply targets Workplace Fairness Act implementation at the end of 2027. Present fair-employment expectations and the future Act’s commencement are separate.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
The regulator links repeat analysis to the prior result: repetition every four years where equality was not met; an employer newly reaching 100 workers at the start of a year has its own first-analysis clock.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
The national 50+ reporting transition depends on the latest certification/confirmation. Regulation 946/2026 also requires an approved equality plan before filing.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandRechecked
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
Current guidance uses a merit-and-requirements assessment, not the older arguability wording. Acknowledge within five working days; decide within 60 working days, with a reasoned limited extension where allowed.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruRechecked
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
Correction: the prior 4 August 2026 Supreme Court claim was not supported by the cited evidence and has been removed. Confirmed guidance requires job-category/function schedules and informing workers of salary policy.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
The official interpretation supports a reasoned written response within 30 days and the internal complaint/role-register controls. This is an existing same-work framework, not a newly verified universal public report.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaRechecked
Previously
Equal-remuneration baseline; separate confidential social balance for more than 300 workers
Finding
Correction: Law 25,877 article 25 says more than 300 workers, not 300 or more. The annual social balance is confidential; union delivery is within 30 days after preparation, with a copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

Corrected employer coverage in Argentina and South Korea and withdrew an unsupported Peru court claim. Added Japan’s two-indicator disclosure, practical reporting controls and Slovenia’s dated government plan.

4 Changed11 Practical detail24 Rechecked6 Open verification
All country findings and open points · 45

All 44 countries and the EU baseline have a review record. “Rechecked” confirms only the cited finding, not an exhaustive national-law audit. Open points are explicit for Austria, Hungary, Ireland, Latvia, Israel and Brazil; Greek commencement and Malta’s timing clause also need local confirmation. Document dates and older notification observations remain visible.

European UnionRechecked
Previously
EU baseline in force; national law must be checked
Finding
The EU timetable remains the baseline. National commencement, scope and remedies must be checked separately; a notification count is not a completeness certificate.
Recommended next step
Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
Suggested owner
HR lead with local employment counsel
Timing / condition
EU first reporting: 7 June 2027 for 150+; 7 June 2031 for 100–149, subject to national law.

Evidence: EU-PTD

Open country brief →
SlovakiaRechecked
Previously
Act No. 76/2026 Coll. in force; transitional information rules apply
Finding
Section 18 separates the first 2027 category-average information from the current right to own-pay information. The first 150+ report covers only 1 August–31 December 2026.
Recommended next step
Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
Suggested owner
HR and payroll lead
Timing / condition
31 July 2026 implementation date has passed; first 150+ report due 7 June 2027.

Evidence: SK-ACT76-MPSVR-TEXT

Open country brief →
ItalyRechecked
Previously
Legislative Decree 96/2026 in force; implementing arrangements require separate review
Finding
Decree 96/2026 is published and in force. Publication of the act does not establish that every article 9 implementing arrangement is operational.
Recommended next step
Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First article 9 data collection: 7 June 2027 for 150+, 7 June 2031 for 100–149.

Evidence: IT-GU-96 · IT-DLGS96

Open country brief →
LithuaniaRechecked
Previously
National amendments in force with staged operational dates
Finding
The ministry distinguishes monthly Sodra data from the first annual gap reports in 2028. The 2028 annual report is not permission to defer payroll preparation until 2028.
Recommended next step
Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
Suggested owner
HR and payroll lead
Timing / condition
Pay-system review by 31 December 2026; January 2027 monthly data submitted in February.

Evidence: LT-SADM · LT-SODRA

Open country brief →
FinlandRechecked
Previously
Government bill pending — not enacted law
Finding
HE 129/2026 remains a proposal in the reviewed project record. The proposed payroll-input start and separate gap-report dates must not be merged.
Recommended next step
Prepare a payroll-field mapping against the Incomes Register guidance, labelled as preparation pending enactment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Proposed input start 1 January 2027 for 150+; proposed first separate filing 2 May 2028.

Evidence: FI-HE129 · FI-GOVERNMENT-PROJECT · FI-INCOMES-REGISTER

Open country brief →
FranceRechecked
Previously
Bill presented to Cabinet; enactment not verified
Finding
The 10 September Cabinet text proposes retaining the existing private-sector index in 2027 and moving to the new framework in 2028. It is a bill, not enacted transition law.
Recommended next step
Keep the current index workflow funded and prepare a separate change plan; do not cancel existing reporting because a replacement has been announced.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue current index dates; proposed 2028 transition remains conditional.

Evidence: FR-CABINET-PTD-BILL

Open country brief →
GermanyRechecked
Previously
Preparatory government work and opposition motion documented
Finding
The Bundestag’s 9 September item concerns opposition motion 21/7916 requesting legislation. It creates no employer duty.
Recommended next step
Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: DE-BT-MOTION-21-7916

Open country brief →
PolandRechecked
Previously
Recruitment duties active; wider UC127 proposal remains a draft
Finding
UC127 still records planned Cabinet adoption in Q4 2026. Existing recruitment-pay information must continue independently of this wider draft.
Recommended next step
Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
Suggested owner
HR lead with local employment counsel
Timing / condition
Recruitment duties already apply; Q4 2026 is a government planning date.

Evidence: PL-KPRM-UC127 · PL-PIP-RECRUITMENT-CURRENT

Open country brief →
SpainPractical detail
Previously
Existing register and audit rules confirmed; wider transposition not established
Finding
RD 902/2020 article 5 requires consultation with worker representatives at least ten days before creating or changing the pay register. Register, equality-plan audit and the EU 5% condition are distinct.
Recommended next step
Add a consultation checkpoint before payroll signs off a register change; retain the invitation, consultation record and final register.
Suggested owner
HR and payroll lead
Timing / condition
At least ten days before the register is created or modified.

Evidence: ES-RD902-CONSOLIDATED

Open country brief →
NetherlandsRechecked
Previously
Government bill awaits both chambers; start date conditional
Finding
Government guidance still makes the 1 January 2027 start conditional on parliamentary approval. This review does not establish a final act.
Recommended next step
Prepare job-value groups, applicant information and data owners, but label the implementation calendar as conditional.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: NL-GOV-PTD-BILL

Open country brief →
BelgiumPractical detail
Previously
6 measures notified; federal completeness not established
Finding
Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
Recommended next step
Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Evidence: BE-FPS-PAY-GAP

Open country brief →
SwedenRechecked
Previously
Renegotiation and preparation documented; final legislation not verified
Finding
The Equality Ombudsman still distinguishes preparatory work from finished legislation. Existing pay-survey duties are not suspended by the EU implementation debate.
Recommended next step
Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Continue the existing annual cycle; no new enacted commencement date confirmed here.

Evidence: SE-DO-PTD-GUIDANCE

Open country brief →
DenmarkRechecked
Previously
Ministerial answer clarifies proposed reporting; not enacted law
Finding
The parliamentary question and answer describe proposed reporting, including a conditional 50–99-worker category. They are not an enacted filing instruction.
Recommended next step
Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
Suggested owner
HR lead with local employment counsel
Timing / condition
The reviewed 2031 proposal is conditional; confirm final law before implementation.

Evidence: DK-FT-CONSULTATION · DK-FT-BEU85-ANSWER

Open country brief →
AustriaOpen verification
Previously
8 measures notified; economy-wide completeness not established
Finding
Section 11a confirms a biennial anonymised income report and first-quarter delivery. Official guidance and the statutory-search wording disagree at exactly 150 workers; the current section 63 could not be fully retrieved.
Recommended next step
Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
Suggested owner
HR lead with local employment counsel
Timing / condition
Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Evidence: AT-GLBG-11A · AT-USP-INCOME-REPORT

Open country brief →
CzechiaRechecked
Previously
Government-approved transposition proposal; enactment not verified
Finding
The 31 August ministry announcement records a government-approved proposal. Its 2028/2031 reporting timetable still needs the final parliamentary act.
Recommended next step
Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
Suggested owner
HR lead with local employment counsel
Timing / condition
2028 for 150+ and 2031 for 100–149 remain proposed first-report years.

Evidence: CZ-MPSV-PTD-BILL

Open country brief →
HungaryOpen verification
Previously
Current transposition position unverified
Finding
The verified Labour Code baseline is retained. The autumn programme was blocked by CAPTCHA and the current full-transposition outcome remains unverified; the older zero-notification observation is not refreshed.
Recommended next step
Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
Suggested owner
HR lead with local employment counsel
Timing / condition
No new employer filing deadline is asserted.

Evidence: HU-LABOUR-CODE-SECTION12

Open country brief →
PortugalRechecked
Previously
Existing equal-pay law applies; partial-transposition consultation draft
Finding
BTE Separata 26/2026 expressly labels the text a proposal for public consultation and partial transposition. Its proposed 50–249 reporting bracket is not a current legal instruction.
Recommended next step
Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: PT-BTE-SEPARATA26-2026 · PT-LAW60

Open country brief →
IrelandOpen verification
Previously
Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified
Finding
The complete June ministerial answer supports continuing annual publication and describes mandatory central-portal filing as dependent on amendment. It cannot establish the September enactment position.
Recommended next step
Preserve the employer’s published report and proof of the applicable deadline; verify any enacted portal mandate separately before changing the submission workflow.
Suggested owner
HR lead with local employment counsel
Timing / condition
Use the entity’s statutory reporting cycle; current full transposition and central-portal mandate remain open.

Evidence: IE-PTD-MINISTER-20260616 · IE-EMPLOYMENT-EQUALITY-CONSOLIDATION

Open country brief →
RomaniaRechecked
Previously
L445/2026 in Senate committees; procedural dates are not employer deadlines
Finding
L445/2026 remains recorded in Senate committees. The 2 October tacit-adoption milestone belongs to parliamentary procedure, not to employers.
Recommended next step
Track the final text and commencement article; prepare data without treating the parliamentary milestone as a filing deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
2 October 2026: procedural monitoring point only.

Evidence: RO-SENATE-L445

Open country brief →
BulgariaPractical detail
Previously
Consultation closed; final enactment not established by the record
Finding
The official consultation export now provides an inspectable history: closed on 18 June and a response summary recorded on 11 August. No final Council act is listed in this export.
Recommended next step
Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: BG-CONSULTATION-12386-EXPORT

Open country brief →
CroatiaRechecked
Previously
Job-evaluation guidance available; legislative alignment in progress
Finding
The ministry lists job-evaluation tools for small, medium and large employers and updated 9 September supporting files. Tools support preparation; they do not prove enacted transposition.
Recommended next step
Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Preparation can begin now; binding dates require the final law.

Evidence: HR-MROSP-JOB-EVALUATION · HR-MROSP-JOB-EVALUATION-FAQ-20260909

Open country brief →
SloveniaChanged
Previously
16 measures notified; completeness not verified
Finding
On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.
Recommended next step
Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
Suggested owner
HR lead with local employment counsel
Timing / condition
End of 2026 is the ministry’s planning target, not an employer deadline.

Evidence: SI-GOV-PLAN-20260911

Open country brief →
EstoniaRechecked
Previously
Partial pay-transparency duties active; broader package not transposed in ministry guidance
Finding
The ministry separates active recruitment changes from the wider paused package. Older implementation-plan paragraphs on the same page should not be read as current enacted reporting.
Recommended next step
Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current partial duties apply now; no new full-package commencement confirmed.

Evidence: EE-MKM-CURRENT-STATUS · EE-ACT-2026

Open country brief →
LatviaOpen verification
Previously
TAP 26-TA-700 remains a draft in the reviewed record
Finding
The retained TAP draft and proposed dates remain labelled as proposals. Today’s full draft retrieval failed, so a later adoption or revision could not be ruled out.
Recommended next step
Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
Suggested owner
HR lead with local employment counsel
Timing / condition
Draft 2027/2031 dates are not confirmed employer deadlines.

Evidence: LV-TAP-26-TA-700 · LV-TAP-26-TA-700-DRAFT

Open country brief →
GreeceRechecked
Previously
Law 5316/2026 published; confirm applicable commencement provisions
Finding
The parliamentary record confirms Law 5316 and Gazette 105 A/6 July 2026. This review of the record does not close the outstanding article-by-article commencement and implementing-decision check.
Recommended next step
Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific commencement and filing date still require confirmation.

Evidence: GR-PARLIAMENT-5316

Open country brief →
CyprusRechecked
Previously
Consultation closed; revised bill available
Finding
The official consultation is closed: published 5 November 2025, comments ended 4 December 2025. A bill titled “2026” is not by itself an enacted 2026 law.
Recommended next step
Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
Suggested owner
HR lead with local employment counsel
Timing / condition
Consultation is no longer open; no final commencement verified in this source.

Evidence: CY-PTD-CONSULTATION

Open country brief →
MaltaRechecked
Previously
LN 173/2026 published; reporting timing needs careful application
Finding
Regulation 9 specifies the first reference periods explicitly: 2026 for 150+ and 2030 for 100–149. The separate fourteen-working-day wording still needs local operational clarification.
Recommended next step
Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
Suggested owner
HR lead with local employment counsel
Timing / condition
First reports by 7 June 2027 / 7 June 2031; resolve the additional timing clause locally.

Evidence: MT-LN173-PDF

Open country brief →
LuxembourgRechecked
Previously
Parliamentary discussion documented; enacted transposition not verified
Finding
The Chamber record is a committee discussion requested by a political group. It cannot establish a transposition act or an employer commencement date.
Recommended next step
Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prepare now; confirm national commencement before applying a new deadline.

Evidence: LU-CHD-MEETING-1014627

Open country brief →
United KingdomPractical detail
Previously
Great Britain 250+ gender-pay-gap reporting active
Finding
The 250+ Great Britain reporting duty is mandatory. Gender-pay-gap action plans are currently voluntary; the stated spring-2027 mandatory start is subject to legislation.
Recommended next step
Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current snapshot cycle: 30 March 2027 for covered public bodies; 4 April 2027 for private/voluntary employers.

Evidence: UK-GPG-GOV

Open country brief →
United StatesPractical detail
Previously
Federal equal-pay baseline plus state and local transparency rules
Finding
California requires an in-post pay scale for covered 15+ employers, including roles potentially filled remotely in California. Its 100+ pay-data reports are separate from federal EEO-1. This is not a complete state-by-state survey.
Recommended next step
Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
Suggested owner
HR lead with local employment counsel
Timing / condition
California 2025-data deadline was 13 May 2026: check any missing receipt now. Pay scale belongs in each covered posting.

Evidence: US-EEOC-PAY · US-CA-DIR-EQUAL-PAY · US-CA-CRD-REPORTING

Open country brief →
AustraliaPractical detail
Previously
WGEA 100+ reporting active; 500+ target duties also apply
Finding
WGEA reporting requires CEO sign-off and sharing specified reports. Directly employing relevant employers with 500+ workers also choose three gender-equality targets and have three years to meet them or demonstrate improvement.
Recommended next step
Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
Suggested owner
CEO, HR reporting lead and governing body
Timing / condition
Standard reporting window 1 April–31 May; target period runs three years from selection. Confirm the entity’s portal cycle.

Evidence: AU-WGEA-REPORTING · AU-WGEA-COMPLIANCE · AU-WGEA-TARGETS

Open country brief →
CanadaPractical detail
Previously
Federal 10+ proactive pay equity and separate 100+ LEEP reporting active
Finding
The regulator’s page, modified 11 September, distinguishes federal 10+ proactive pay equity from other regimes. Plans are normally due within three years of becoming subject and updated at least every five years.
Recommended next step
Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
Suggested owner
HR lead with local employment counsel
Timing / condition
Entity-specific three- and five-year plan clocks; verify annual-statement and LEEP dates separately.

Evidence: CA-PAY-EQUITY · CA-LEEP

Open country brief →
BrazilOpen verification
Previously
100+ semi-annual reporting active; sixth-report availability not confirmed
Finding
The official sixth-report notice confirms the 3–31 August information-update window for 100+ employers. Today’s review did not establish that the sixth report is already available for every employer.
Recommended next step
Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
Suggested owner
HR lead with local employment counsel
Timing / condition
September publication cycle; a precise availability date remains unverified.

Evidence: BR-MTE-SIXTH-REPORT-2026 · BR-LAW14611

Open country brief →
JapanPractical detail
Previously
Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026
Finding
From April 2026, 101+ regular-worker employers disclose both the gender wage gap and the women-manager ratio. Additional required indicators depend on size; timing follows the employer’s financial year.
Recommended next step
Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
Suggested owner
HR and payroll lead
Timing / condition
Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Evidence: JP-MHLW-DISCLOSURE-2026

Open country brief →
South KoreaCorrection
Previously
Equal-value pay rule generally applies from 5 regular workers; no universal public report
Finding
Correction: the old under-five-worker exception was deleted in 2018. Article 8 equal-value pay cannot be presented as starting only at five regular workers; the decree’s specific exceptions still need scope checking.
Recommended next step
Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
Suggested owner
HR lead with local employment counsel
Timing / condition
Correct scope now; no universal public-report filing date follows from article 8.

Evidence: KR-EQUAL-EMPLOYMENT-ACT-TEXT · KR-EQUAL-EMPLOYMENT-DECREE

Open country brief →
IsraelOpen verification
Previously
Annual reporting active for 519+ employers and specified entities
Finding
The retained 519+ and specified-entity framework remains the baseline. Current regulator instructions and any 2026 deadline extension were not successfully verified; the old early-June wording must not be treated as a confirmed current deadline.
Recommended next step
Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
Suggested owner
HR lead with local employment counsel
Timing / condition
Current-cycle publication deadline and any extension: verification required.

Evidence: IL-KNESSET-EQUAL-PAY

Open country brief →
South AfricaPractical detail
Previously
2026 EEA2/EEA4 reporting open for designated employers
Finding
The live 2026 portal accepts EEA2 and EEA4 only, not EEA12/13. It requires CEO approval and an acknowledgement of receipt; no amendment is allowed after final submission.
Recommended next step
Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
Suggested owner
CEO and Employment Equity reporting officer
Timing / condition
Manual/post: 1 October 2026. Online: 15 January 2027 at 23:59, as displayed by the regulator.

Evidence: ZA-DEL-EE-ONLINE-2026

Open country brief →
IndiaPractical detail
Previously
Code on Wages section 3 in force; no universal public reporting
Finding
The official explanation explicitly includes transgender identity in section 3 gender-discrimination controls for wages and recruitment. A generic male/female-only policy misses that scope.
Recommended next step
Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
Suggested owner
HR lead with local employment counsel
Timing / condition
Apply the existing section 3 controls now; no universal pay-gap filing date asserted.

Evidence: IN-PIB-WAGES-GENDER · IN-CODE-WAGES-S3

Open country brief →
SingaporeRechecked
Previously
Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force
Finding
The MOM parliamentary reply targets Workplace Fairness Act implementation at the end of 2027. Present fair-employment expectations and the future Act’s commencement are separate.
Recommended next step
Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
Suggested owner
HR lead with local employment counsel
Timing / condition
End-2027 target remains subject to commencement arrangements; no universal report deadline.

Evidence: SG-MOM-WFA · SG-MOM-TGFEP

Open country brief →
SwitzerlandRechecked
Previously
100+ headcount equal-pay analysis framework active through 30 June 2032
Finding
The regulator links repeat analysis to the prior result: repetition every four years where equality was not met; an employer newly reaching 100 workers at the start of a year has its own first-analysis clock.
Recommended next step
Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Evidence: CH-EBG-REPEAT

Open country brief →
IcelandRechecked
Previously
National 50+ reporting framework in force; transition depends on prior certification
Finding
The national 50+ reporting transition depends on the latest certification/confirmation. Regulation 946/2026 also requires an approved equality plan before filing.
Recommended next step
Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
Suggested owner
HR lead with local employment counsel
Timing / condition
Prior certificate/confirmation: three years after the latest one. Neither held: before 1 March 2027.

Evidence: IS-REGULATION-946-2026 · IS-ALTHINGI-LAW53

Open country brief →
New ZealandPractical detail
Previously
Amended equal-pay and pay-equity claim process active; no universal public report
Finding
Current guidance uses a merit-and-requirements assessment, not the older arguability wording. Acknowledge within five working days; decide within 60 working days, with a reasoned limited extension where allowed.
Recommended next step
Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
Suggested owner
HR lead with local employment counsel
Timing / condition
5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Evidence: NZ-EMPLOYMENT-CLAIM-RESPONSE

Open country brief →
PeruCorrection
Previously
Job-category and equal-value pay framework active without a general headcount threshold
Finding
Correction: the prior 4 August 2026 Supreme Court claim was not supported by the cited evidence and has been removed. Confirmed guidance requires job-category/function schedules and informing workers of salary policy.
Recommended next step
Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
Suggested owner
HR lead with local employment counsel
Timing / condition
Maintain the existing controls now; no new court-created deadline is asserted.

Evidence: PE-CONGRESS-LAW30709

Open country brief →
ChileRechecked
Previously
Same-work pay rule active; 10+ complaint procedure and 200+ role register
Finding
The official interpretation supports a reasoned written response within 30 days and the internal complaint/role-register controls. This is an existing same-work framework, not a newly verified universal public report.
Recommended next step
Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
Suggested owner
HR lead with local employment counsel
Timing / condition
Reasoned written response within 30 days of the complaint.

Evidence: CL-DT-EQUAL-PAY-PROCEDURE

Open country brief →
ArgentinaCorrection
Previously
Equal-remuneration baseline without a headcount threshold; separate 300+ confidential balance social
Finding
Correction: Law 25,877 article 25 says more than 300 workers, not 300 or more. The annual social balance is confidential; union delivery is within 30 days after preparation, with a copy to the labour authority.
Recommended next step
Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
Suggested owner
HR lead with local employment counsel
Timing / condition
Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Evidence: AR-LAW25877-CURRENT

Open country brief →

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Start with country, then act

The map is the entry point. The process below shows what happens after a country is selected.

01

Start

Select a country

Click the map or use the country picker when the employer has people there.

View map
02

Then

Read employer impact

Check status, deadlines, employee rights, reporting duties and source confidence.

03

Next

Open local material

Use local-language country pages when the employer needs country-specific action.

Country library
04

Finish

Export planning data

Download the tracker when HR, legal, reward or payroll need a shared worklist.

Export XLSX

A real world map first, country details second

Use the map the way people naturally think about global work: click a country, see what is in force, what is coming and what the employer needs to prepare.

Loading country records
Loading the world map...

One reporting spine for CSRD, employee requests and country duties

ACLASA connects pay transparency, ESRS S1 remuneration metrics, hourly remuneration, employee information requests and global country reporting in one operating model.

CSRD / ESRS S1

Sustainability reporting needs payroll-grade evidence

Pay gap and remuneration-ratio outputs use controlled populations, components, periods and approvals.

Employee right

EU requests need a clear answer process

Workers need written, accessible information without exposing another person’s pay.

Safe factors

Explanations must be objective and documented

ACLASA separates defensible factors from salary history, negotiation power and historical titles.

Payroll spine

Correct pay and hours data decides credibility

Payroll reconciles pay codes, hours, FTE, retro corrections and exclusions before reports or responses go out.

Clear enough for a small firm, deep enough for a global employer

The public tracker gives everyone a starting point. Larger employers can add local country files, source refreshes, language views and reporting packs from the same dataset.

Public

Know where to look first

Country status, plain obligations, start-stop-more actions and XLSX export for planning.

Company

Run many countries calmly

Local country files, English group views, source refreshes and clear ownership of next actions.

Codes

Use the right work language

EU starts with ISCO/EIGE/ACLASA. The US, Brazil, Australia, Canada and the UK need their own reporting and occupation logic.

Watch

Every country has a place

Countries without a strong public duty stay visible as monitored, so global teams can keep one inventory.

What clients see in the first minute

Board

Where are we exposed?

See which countries are already in force, which are moving through legislation and which need immediate data preparation.

HR

What must change in hiring?

Salary-range communication, salary-history bans and neutral job ads are shown as concrete actions, not legal jargon.

Reward

How do we classify work?

ACLASA keeps the sequence stable: work evidence, objective evaluation, equal-value category, ACLASA band, ISCO/ESCO context and country rules.

Legal

Can we evidence it?

Every country card carries official sources, status, deadlines, local language text and an English export layer.

Find the country, risk or readiness state

The list uses the same data as the map and export. Use it when you need sources, deadlines and the detailed employer checklist.

Country
Historical content basis 2026-10-08

Daily source status

Source check completed 8 October 2026. Historical content basis: 8 October 2026.

The check on 8 October 2026 compared 89 document bodies within 110 observations in 45 country and EU records. 5 checks remain unresolved. The availability monitor ran on 8 October 2026: 17 technical findings across 110 routes. Statutory dates and country legal-review dates remain unchanged. 89 document bodies / 110 bounded observations / 45 country and EU records; 30 scoped no-change findings; 5 unresolved checks. This is not a complete country-law review. Open verification: 21 · Practical detail: 10.

Historical content basis
Last official-source check
Status
Source freshness checks blocked or unresolved
0 changed 30 no change 5 blocked

HTTP availability is not legal verification. The scheduled monitor has no deployment step; publication requires a separate tested and approved release.

The source register retains 110 overdue review dates. These are separate from technical availability findings; this bounded check does not renew legal-review dates.

Austria: Current RIS GlBG section 63(6) was now retrieved: it says more than 150 workers; USP says at least 150. This resolves the previous access gap but leaves a source conflict to disclose. The governed B-GlBG is federal-sector law and is not evidence of economy-wide transposition. Malta: LN 173/2026 text covers public/private employers and workers, with recruitment rules for applicants. Regulation 6 requires written response in eight days and retains data five years. Regulation 9 sets 2027/2031 reporting bands but also a fourteen-working-day submission clause; a single June filing date is incomplete without regulator clarification. Greece: The official Parliament record was re-read on 8 October. It confirms Law 5316/2026, the 2 July vote and Gazette 105 A of 6 July 2026. The page does not provide a final article-by-article Gazette body, so the enacted status is confirmed while specific employer commencement and filing clauses remain open for local verification. United States: Federal EPA covers substantially equal work and all compensation; Title VII generally starts at 15 employees. EEO-1 page says 2024 closed and 2025 updates pending. California 15+ in-post scales and 100+ pay-data duties are separate; 2025 reports were due 13 May 2026. DIR also confirms employee scale requests, anti-retaliation and wage recovery.

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ACLASA core method

3,173 role profiles. One method across TalentAccess and ACLASA.

The country tracker uses the same logic as the ACLASA and TalentAccess methodology catalog: describe the work, compare it through factors, assign the band, then connect the right country rule.

Country index

European Union
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

EU baseline in force; national law must be checked

Situation in brief

Directive (EU) 2023/970 sets the common EU framework for equal pay, recruitment transparency, worker information rights, employer reporting and enforcement. The transposition deadline passed on 7 June 2026, but employer duties must be read through each country's enacted law.

What applies now
  • The Directive is the common legal baseline for all 27 EU Member States.
  • A Member State's notification to EUR-Lex does not prove that transposition is complete or legally correct.
Next deadline or monitoring point

The first Directive reporting date is 7 June 2027 for employers with at least 150 workers; the first 100-149 worker date is 7 June 2031, subject to national implementation.

Employer actions
  • Create an entity-by-country obligation register: headcount, payroll period, worker requests, reporting owner and local legal source.
  • Build objective gender-neutral pay structures and equal-value categories.
  • Prepare recruitment, worker-information, reporting and remediation workflows.
  • Confirm the enacted national rule before applying a threshold, deadline or sanction.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Slovakia
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance. This review used the Ministry's dated Act text and did not exhaustively check subsequent amendments; confirm the current consolidated text before acting.

Legislative stage

Act No. 76/2026 Coll. in force; transitional information rules apply

Situation in brief

Act No. 76/2026 Coll. took effect on 7 June 2026. Section 6 separates information about an employee's own pay from sex-disaggregated category averages. Under section 18(2), category-average information is first provided for 2027. This does not create a separate 1 January commencement date for own-pay information.

What applies now
  • Candidates must receive starting-pay or range information and must not be asked about pay history.
  • Workers have information rights; employers need objective criteria, annual rights notice, accessible responses and evidence for pay differences.
Next deadline or monitoring point

Information requests have a two-month response period. Employers with 150+ workers first report by 7 June 2027 for 1 August–31 December 2026; 100–149 first report by 7 June 2031 for 2030. Subsequent section 8 reports are due 15 April, annually for 250+ and every three years for 100–249.

Employer actions
  • Check the 31 July pay-structure implementation evidence and preserve August–December payroll by equal-value category; start a two-month request-response log.
  • Confirm that the remuneration structure and evaluation criteria are documented and gender-neutral.
  • Prepare two-month worker-information responses and the annual rights notice.
  • Prepare reportable data by equal-value category and a controlled 5% joint-assessment workflow.
Employee rights

Provide the worker's own pay level within two months of a request. Sex-disaggregated average pay for the relevant equal-value category is first provided for 2027 under section 18(2), subject to the two-month response period. Incomplete information must be corrected or explained within 30 days.

Reporting

250+ annually; 150-249 every three years; 100-149 every three years; under 100 voluntarily, with special first-report dates in the Act.

Enforcement

Specific failure to report after an additional cure period carries EUR 4,000-8,000; labour-inspection exposure may be higher under the applicable inspection regime. Civil remedies and burden-of-proof consequences also apply.

Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Italy
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

Italy overlay: evaluate actual work first, assign the ACLASA 1,200-point result and B01-B15 band, record ISCO major/unit context, then map the applicable CCNL category and level with evidence. A CCNL or ISCO label is not a substitute for analytical job evaluation or a conclusive equal-value determination.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Legislative Decree 96/2026 in force; implementing arrangements require separate review

Situation in brief

Legislative Decree 96/2026 was published on 1 June and took effect on 7 June 2026. Article 7 provides written category-average pay information within two months, with requests no more than once annually and annual notice of the right. The review covered the original decree; later amendments and implementing arrangements were not exhaustively audited.

What applies now
  • Use the decree and current Italian equal-opportunities framework, not a draft summary.
  • CCNL level, ISCO code and ACLASA band are related controls but none alone proves work of equal value.
Next deadline or monitoring point

Article 9(9) sets data collection by 7 June 2027 for 150+ employees and by 7 June 2031 for 100–149; annual thereafter for 250+ and every three years for 100–249. Confirm the implementing arrangements required separately by article 9(4).

Employer actions
  • Prepare annual and hourly pay components, equal-value groupings and the worker-information response process; obtain the applicable reporting instructions before submission.
  • Evaluate actual work with objective gender-neutral factors before mapping classifications.
  • Record ISCO major and unit group, ACLASA score/band and the relevant CCNL level with a documented crosswalk rationale.
  • Prepare recruitment, worker-information, reporting and remediation evidence in Italian and English group views.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Lithuania
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

National amendments in force with staged operational dates

Situation in brief

Lithuania enacted a pay-transparency amendment package. Employer pay-system design, candidate information, equal-value grouping and Sodra data flows are an active implementation programme, with obligations and data changes staged across 2026-2028.

What applies now
  • Use the official SADM and Sodra implementation material together with the underlying enacted acts.
  • Do not compress the staged dates into one generic EU deadline.
Next deadline or monitoring point

Review pay systems by 31 December 2026. All employers start monthly Sodra submissions with January 2027 data, submitted in February. Separately, Sodra provides first annual pay-gap reports in 2028 for 2027 (150+ workers) and 2031 for 2030 (100–149).

Employer actions
  • Assign payroll fields to occupational groups and test the January 2027 data extract; review the pay system and workers’ access process.
  • Review the pay system and equal-value group definitions.
  • Remove salary-history questions and prepare candidate and worker information workflows.
  • Map Sodra data fields, owners and validation controls for the staged reporting changes.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Finland
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Government bill pending — not enacted law

Situation in brief

The ministry published a voluntary gender-neutral job-evaluation model on 3 September 2026. Incomes Register guidance updated on 8 September sets out reporting preparations under HE 129/2026. The bill remains before Parliament; 1 January 2027 is proposed commencement, not enacted law.

What applies now
  • Existing Finnish equality and pay-survey duties continue.
  • The new voluntary evaluation model supports equal-value work comparisons alongside existing evaluation systems.
Next deadline or monitoring point

Proposed timetable: payroll reporting from 1 January 2027 for 150+ workers and 1 January 2030 for 100–149; first separate pay-gap submissions on 2 May 2028 (2027 data) and 2 May 2031 (2030 data), respectively. Subject to enactment.

Employer actions
  • Prepare a payroll-field mapping against the Incomes Register guidance, labelled as preparation pending enactment.
  • Maintain current Finnish equality-plan and pay-survey compliance.
  • Run a readiness gap assessment against HE 129/2026 without describing it as law.
  • Update the tracker immediately when the final act and commencement provisions are published.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

France
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Government bill no. 944 deposited in the Senate; accelerated procedure, not enacted law

Situation in brief

France has an existing professional-equality index. Government bill no. 944, intended to transpose Directive (EU) 2023/970, was deposited in the Senate on 10 September 2026 and placed under the accelerated procedure. First reading remains pending, so the bill does not yet create new employer duties.

What applies now
  • Continue applying the existing French professional-equality index and related consultation and remediation duties.
  • Treat the 50+ scope, new indicators and staged 2027–2028 transition in bill no. 944 as proposed measures until Parliament adopts and the Journal officiel publishes the final law.
Next deadline or monitoring point

Continue current index deadlines. Monitor Senate first reading, amendments, final adoption, promulgation and implementing decrees before activating the proposed bill-based obligations.

Employer actions
  • Keep the current French index process funded for the existing cycle.
  • Map current payroll and job-value data to the bill’s proposed equal-value categories and recruitment information fields without presenting the proposal as binding.
  • Assign French legal counsel to review the adopted text, commencement provisions and decrees before changing policy or reporting.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Germany
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Preparatory government work and opposition motion documented

Situation in brief

The government answer reported on 16 July 2026 describes preparatory transposition work. A Die Linke motion reported on 9 September calls for legislation; it is an opposition motion, not a government bill or enacted act. The cited review does not verify comprehensive enacted transposition.

What applies now
  • Apply existing German equal-pay, information and co-determination rules.
  • Treat the Directive implementation as unresolved until a final national act is published and reviewed.
Next deadline or monitoring point

Maintain existing German duties and monitor government and parliamentary records weekly. No employer commencement date follows from the opposition motion.

Employer actions
  • Keep the existing German information and equal-pay controls; prepare an implementation register that only activates new duties after an enacted text is confirmed.
  • Continue current Entgelttransparenzgesetz and equal-treatment compliance.
  • Prepare a gap assessment against the Directive without treating policy statements as law.
  • Re-baseline immediately when a formal bill or act is published.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Poland
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Recruitment duties active; wider UC127 proposal remains a draft

Situation in brief

Recruitment amendments apply from 24 December 2025: initial pay or range information, gender-neutral recruitment wording and a restriction on salary-history questions. The official government register separately lists wider proposal UC127 as a draft. This bounded review does not establish complete enacted transposition.

What applies now
  • The recruitment duties are binding now.
  • The wider equal-value, information, reporting and enforcement package remains a separate monitoring item.
Next deadline or monitoring point

The UC127 registry gives Q4 2026 as planned Cabinet adoption. This is a planning date, not enactment or an employer commencement deadline; continue current recruitment duties.

Employer actions
  • Audit job advertisements and information sent before interviews; keep the wider reporting design marked as draft.
  • Audit job adverts, candidate communications and salary-history questions now.
  • Prepare the wider Directive data and equal-value framework.
  • Keep recruitment compliance separate from unconfirmed full transposition.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Spain
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

RD 902/2020 active; RD 723/2026 effective 5 October 2026; EU PTD completeness unverified

Situation in brief

Royal Decree 902/2020 has been Spain's binding pay-equality and remuneration-transparency layer since 14 April 2021. Royal Decree 723/2026 was published on 15 September 2026 and has applied since 5 October 2026. It partially transposes Directive (EU) 2019/1152, not Directive (EU) 2023/970. It adds an operational written-information layer that improves pay-data readiness and explainability for future EU Pay Transparency work, but it does not prove complete transposition of Directive (EU) 2023/970.

What applies now
  • All employers within the scope of Royal Decree 902/2020 must maintain a remuneration register covering the workforce, including management and senior executives.
  • Employers required to maintain an equality plan must include the applicable pay audit and equal-value assessment in that plan.
  • Before creating or changing the remuneration register, consult the legal worker representatives at least ten days in advance under Article 5 of Royal Decree 902/2020 and retain the invitation, consultation record and final register.
  • Confirm locally how the applicable collective agreement and autonomous-community rules affect implementation.
  • Royal Decree 723/2026 has applied since 5 October 2026. Use the written-information workflow for employment relationships within scope and retain proof of delivery.
  • Keep Spain's EU Pay Transparency status marked as notified measures with completeness unverified.
Next deadline or monitoring point

Since 5 October 2026, operate the RD 723/2026 information pack. For new employment relationships, provide the required written information before work starts; provide later changes as soon as possible and no later than the day they take effect.

Employer actions
  • Maintain the Royal Decree 902/2020 remuneration register for all employers within scope, including management and senior executives.
  • Keep the applicable pay audit and equal-value assessment within the equality plan.
  • Schedule the Article 5 consultation with legal worker representatives at least ten days before creating or changing the remuneration register; retain the invitation, consultation record and final register.
  • Confirm the effects of the applicable collective agreement and autonomous-community rules with local counsel.
  • State base salary and every salary supplement separately, with payment frequency and method.
  • Document the calculation method and entitlement criteria for every variable-pay component.
  • Document overtime arrangements and remuneration.
  • Disclose the existence and operating rules of algorithmic or automated systems that determine, set, vary or modify pay.
  • Retain accessible proof that the written information was delivered; align the fields with the remuneration register without treating RD 723/2026 as EU Pay Transparency transposition.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Netherlands
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Government bill 36949 pending — no enacted Directive law confirmed

Situation in brief

Bill 36949 remains before the Dutch parliament. The Tweede Kamer scheduled plenary debates for 7 December 2026 and 11 January 2027; both chambers must still approve the bill, so these are legislative milestones rather than employer compliance deadlines.

What applies now
  • Existing Dutch equal-treatment, works-council and privacy rules continue to apply.
  • Bill 36949 is pending and does not yet create a confirmed national commencement date.
Next deadline or monitoring point

Legislative watch: Tweede Kamer plenary debates scheduled for 7 December 2026 and 11 January 2027. Confirm the final act and commencement before treating any date as binding.

Employer actions
  • Prepare a provisional 100+ reporting-scope map, including the proposal's headcount treatment, but keep it labelled draft.
  • Identify equal-value gaps at or above 5% and assign a six-month remediation owner as readiness work.
  • Track Bill 36949 through both chambers; activate legal duties only from the final published act.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Belgium
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Existing biennial pay-structure report for covered 50+ employers; full transposition not confirmed

Situation in brief

Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.

What applies now
  • Existing Belgian guidance requires a pay-structure analysis every two financial years for covered employers averaging at least 50 workers: abbreviated model for 50–99, full model from 100. The mediator is optional.
  • Apply existing Belgian federal, regional and collective obligations that cover the employer.
Next deadline or monitoring point

Biennial reporting cycle; derive the next delivery from the employer’s financial years and consultation timetable.

Employer actions
  • Confirm the statutory headcount calculation and use the correct model; schedule presentation to the works council or trade-union delegation.
  • Map the employing entity, region, sector and collective agreement.
  • Maintain existing pay-gap and social-dialogue controls.
  • Commission a Belgian scope review before treating a notified measure as applicable.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Sweden
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Renegotiation and preparation documented; final legislation not verified

Situation in brief

The government's no-bill and renegotiation announcement was on 26 March 2026. The 8 June announcement concerned resumed preparation and promotional work through the Equality Ombudsman. Guidance updated on 17 June said legislation was incomplete. These dated records do not establish an exhaustive September legislative status.

What applies now
  • Continue the established annual gender pay survey and remediation process.
  • Do not present the abandoned or delayed proposal, or the NIM count, as complete transposition.
Next deadline or monitoring point

Continue existing Swedish pay-survey duties and monitor the current legislative record weekly. The historical NIM count is not a fresh completeness assessment.

Employer actions
  • Maintain the annual pay-survey workflow and documented equal-value grouping; keep draft reporting fields separate.
  • Maintain the Swedish pay-survey process and documented analysis.
  • Prepare Directive recruitment, information and reporting capabilities.
  • Refresh immediately if the Government restarts legislation.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Denmark
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Ministerial answer clarifies proposed reporting; not enacted law

Situation in brief

The ministerial answer dated 27 August 2026 describes proposed reporting for certain employers with 50–99 workers where the same function includes at least eight men and eight women. This is not blanket coverage of every employer with 50+ workers, and enactment is not established by the answer.

What applies now
  • Apply current Danish equal-pay and collective rules.
  • Do not assert Directive-specific duties without a final Danish act.
Next deadline or monitoring point

For that proposed 50–99 group, reporting is described every three years from 2031. Treat this as a proposal and monitor the final legislative text.

Employer actions
  • Keep a separate scenario for the proposed threshold; do not merge it into the current mandatory calendar.
  • Continue current Danish equal-pay and gender-disaggregated pay-statistics duties.
  • Model the consultation draft as a scenario only.
  • Reconcile any final national threshold with the Directive only after enactment.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Austria
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

8 measures notified; economy-wide completeness not established

Situation in brief

EUR-Lex listed eight Austrian measures, but the notification set includes limited or public-sector material and does not establish complete economy-wide transposition. Existing salary-range advertising and equality duties continue.

What applies now
  • Section 11a confirms a biennial anonymised income report and first-quarter delivery. Official guidance and the statutory-search wording disagree at exactly 150 workers; the current section 63 could not be fully retrieved.
  • Apply existing Austrian job-advertisement and equal-treatment duties.
Next deadline or monitoring point

Covered reports go to worker representatives in Q1 following the reporting year; exact 150-worker boundary remains open.

Employer actions
  • Prepare the anonymised report, but obtain the current section 63 scope before deciding coverage for exactly 150 workers.
  • Audit vacancy pay information and objective pay criteria.
  • Prepare the wider Directive dataset and worker-information process.
  • Obtain Austrian legal scope confirmation for notified measures.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Czechia
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Government-approved transposition proposal; enactment not verified

Situation in brief

The Ministry of Labour page, updated on 31 August 2026, confirms government approval of the transposition proposal. The proposal is a substantive legislative step, but government approval does not establish enacted law or a general effective date.

What applies now
  • Existing Czech labour, anti-discrimination and inspection law continues to apply.
  • No complete Directive compliance conclusion is drawn from the notification count.
Next deadline or monitoring point

Proposed first reports: 2028 for 150+ employees and 2031 for 100–149. Proposed frequency is annual for 250+ and every three years for 100–249, subject to enactment.

Employer actions
  • Build a gap between current payroll data and the proposed equal-value reporting fields; retain proposal labels in management papers.
  • Maintain existing equal-pay controls.
  • Prepare objective equal-value categories and reporting data.
  • Obtain a Czech legal review before relying on a notified measure.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Hungary
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Current transposition position unverified

Situation in brief

The official Labour Code text inspected on 13 September 2026 retains section 12 on equal treatment in remuneration and assessment of equal-value work; the displayed consolidation is dated 28 February 2025. This review does not verify September transposition. The autumn programme remained inaccessible behind CAPTCHA. The separate 11 September EUR-Lex observation of zero notified Hungarian measures is unchanged and does not prove that domestic legislation or proposals are absent.

What applies now
  • Section 12 of the inspected Labour Code requires equal treatment in remuneration, including cash and in-kind benefits.
  • Assess equal value using the work, conditions, qualifications, effort, experience and responsibility; do not treat this baseline as confirmation of Directive-specific national duties.
Next deadline or monitoring point

No new national reporting or enactment deadline is asserted. Confirm subsequent Hungarian legislation and the autumn programme before relying on a Directive-specific timetable.

Employer actions
  • Use current equal-treatment controls and ask local counsel for the enacted national text before activating a new reporting date.
  • Preserve objective pay-setting evidence.
  • Prepare the Directive's recruitment and worker-information capabilities.
  • Run a Hungarian legal update when a final act appears.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Portugal
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Existing equal-pay law applies; partial-transposition consultation draft

Situation in brief

BTE Separata 26/2026 of 5 August contains an official partial-transposition draft whose 20-day consultation period has elapsed. It proposes pre-contract pay information, a salary-history ban, information rights and reporting for employers with 50+ workers. Existing Law 60/2018 remains separate from these proposals.

What applies now
  • Continue current Portuguese equality and pay-difference controls.
  • Do not present the EU deadline as enacted Portuguese law.
Next deadline or monitoring point

The draft proposes annual reporting for 250+ and every three years for 50–249. No 1 September commencement follows from the consultation draft; use the final published law for binding dates.

Employer actions
  • Continue existing equal-pay duties and keep a draft-to-final comparison before changing employer thresholds or reporting schedules.
  • Maintain objective job evaluation and the existing equal-remuneration information process.
  • Treat draft recruitment and reporting changes as readiness assumptions only.
  • Replace assumptions with the final published text once enacted.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Ireland
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Existing 50+ gender-pay-gap reporting active; current full-transposition status not verified

Situation in brief

Existing Irish gender-pay-gap reporting remains separate from full Directive transposition. In the official 16 June 2026 answer, the Minister confirmed delayed full transposition and continuing annual publication; central-portal filing was described as following an amendment. The 13 September review read that answer, the consolidation dated 31 May 2025 and the original draft Heads 4 and 5. September enactment and mandatory portal commencement remain unverified.

What applies now
  • Maintain the established gender-pay-gap reporting and equal-remuneration controls under sections 19 and 20A of the inspected consolidation.
  • Treat Heads 4 and 5 as draft measures. Neither the General Scheme nor the April programme proves an enacted September duty.
Next deadline or monitoring point

Follow the employer's applicable statutory Irish reporting deadline. The April 2026 programme separately lists the Pay Transparency Bill and a bill concerning the central reporting portal; that historical programme does not establish a current mandatory portal-filing duty or the absence of subsequent legislation.

Employer actions
  • Preserve the employer’s published report and proof of the applicable deadline; verify any enacted portal mandate separately before changing the submission workflow.
  • Maintain the current annual reporting dataset and publication controls.
  • Prepare objective job-value and worker-information processes; confirm current enacted Directive requirements before applying additional duties.
  • Keep existing reporting separate from draft transposition assumptions.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Romania
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

L445/2026 in Senate committees; procedural dates are not employer deadlines

Situation in brief

The Senate record now lists a 60-day tacit-adoption period ending 17 October 2026, replacing the previously displayed 2 October date. L445/2026 still remains in permanent committees. This is a parliamentary milestone, not an employer compliance date or enacted transposition.

What applies now
  • Existing Romanian labour and anti-discrimination law continues to apply.
  • Directive-specific duties require article-level confirmation in a final national act.
Next deadline or monitoring point

17 October 2026 is the Senate's currently displayed tacit-adoption date. It is not an employer commencement or compliance date; confirm the final act and commencement.

Employer actions
  • Track the final text and commencement article; prepare data without treating the parliamentary milestone as a filing deadline.
  • Continue existing Romanian equal-treatment and pay duties.
  • Track L445/2026 as a draft scenario only.
  • Implement new thresholds or deadlines only after final enactment and publication.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Bulgaria
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Consultation closed; final enactment not established by the record

Situation in brief

Official consultation 12386 ran from 19 May to 18 June 2026 and is inactive. Results are dated 11 August; the final Council of Ministers act field was blank in the reviewed record. This supports a completion-proposal update, not a claim of enacted comprehensive transposition.

What applies now
  • Apply existing Bulgarian equal-pay and non-discrimination law.
  • Do not infer legal completeness or a market pay range from notification or currency status.
Next deadline or monitoring point

Monitor the final government and legislative record weekly. Twelve NIM measures observed on 10 September are a notification count, not proof of legal completeness.

Employer actions
  • Compare the final adopted text, when available, with the consultation; do not treat stakeholder comments as law.
  • Prepare objective equal-value categories and recruitment controls.
  • Verify the notified national measures at article level.
  • Keep market ranges suppressed until a governed EUR anchor is approved.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Croatia
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Job-evaluation guidance available; legislative alignment in progress

Situation in brief

The ministry provides job-evaluation models for small, medium and large enterprises, including guidance dated 9 September 2026. The models assess the job rather than the person. Labour Act alignment is described as in progress; preparatory guidance is not evidence that transposition is already in force.

What applies now
  • Apply current Croatian labour and equality rules.
  • Treat the Directive implementation as unverified until a final official act is published.
Next deadline or monitoring point

Any expected second-half-of-2026 timetable remains conditional. Use the models for preparation and monitor the enacted law for binding dates.

Employer actions
  • Select the model matching employer size and test a small set of real job descriptions with documented factor evidence.
  • Preserve objective pay evidence.
  • Prepare EU-ready recruitment, information and reporting processes.
  • Update after primary-law review.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Slovenia
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Ministry plans transposition by end-2026; final enactment not verified

Situation in brief

On 11 September the ministry announced planned pay-transparency transposition by the end of 2026. This adds a dated national plan to the previous notification-only brief; enactment is not established.

What applies now
  • Existing Slovenian equal-pay and labour-law protections remain active.
  • Any new Directive-specific duty requires confirmation in a final national act.
Next deadline or monitoring point

End of 2026 is the ministry’s planning target, not an employer deadline.

Employer actions
  • Assign a Slovenian implementation owner and prepare job categories and payroll inputs while monitoring Uradni list for the final act.
  • Maintain current equal-pay controls.
  • Prepare objective job-value categories and reporting data.
  • Obtain Slovenian legal review for notified measures.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Estonia
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Partial pay-transparency duties active; broader package not transposed in ministry guidance

Situation in brief

The ministry confirms amendments effective 13 July 2026: written pay or range information before the first interview, a salary-history ban, the right to discuss one's own pay and equal pay for the same or equivalent work absent objective gender-neutral justification. Current ministry guidance distinguishes wider Directive duties not yet transposed. Direct statutory article-by-article verification was limited by the legal-register page.

What applies now
  • Apply the enacted recruitment-transparency amendment and existing Estonian equality law.
  • Do not treat wider Directive duties that ministry guidance identifies as not yet transposed as binding national requirements.
Next deadline or monitoring point

Apply the confirmed partial duties and monitor the wider legislative package. The historical count of 18 NIM measures was not refreshed by this review.

Employer actions
  • Check pay information provided before interviews and salary-history questions; keep wider reporting fields in preparation.
  • Update recruitment pay information and salary-history controls under the enacted rule.
  • Prepare the wider equal-value and reporting architecture.
  • Keep confirmed partial duties visibly separate from wider duties not yet transposed according to ministry guidance.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Latvia
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

TAP 26-TA-700 remains a draft in the reviewed record

Situation in brief

The TAP record documents consultation from 26 March to 9 April, coordination from 27 June to 10 July and opinions on 14 July 2026. The reviewed draft is a planning input; its thresholds and reporting dates are not presented as binding employer duties.

What applies now
  • Apply current Latvian equality and labour rules.
  • Wait for and review a final official transposition act.
Next deadline or monitoring point

Draft reporting starts 7 June 2027 for 250+ annually and 150–249 every three years; for 100–149 it starts 7 June 2031 every three years. All remain subject to enactment.

Employer actions
  • Obtain the current TAP history and final gazette publication before adopting the draft reporting schedule.
  • Maintain objective pay-setting evidence.
  • Prepare EU-ready equal-value and information workflows.
  • Update after primary-law review.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Greece
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Law 5316/2026 published; confirm applicable commencement provisions

Situation in brief

The parliamentary record confirms Law 5316/2026, voted on 2 July and published in Gazette 105 A on 6 July 2026. EUR-Lex records notification on 23 July with a national declaration of completion. These publication and notification records do not independently establish every operative commencement or reporting clause, and national notification is not a Commission conformity assessment.

What applies now
  • Use the published Greek law, not the prior generic EU-monitoring text.
  • The Member State's completion declaration is not a Commission conformity finding.
Next deadline or monitoring point

Confirm the first size-based filing date, commencement provisions and implementing decisions in the Greek act before relying on a specific employer deadline.

Employer actions
  • Have local counsel identify the applicable articles and filing instructions for each legal entity before setting its deadline.
  • Confirm the applicable commencement provisions before applying the enacted recruitment and worker-information rules.
  • Build equal-value categories and reporting data under the Greek definitions.
  • Verify implementation decisions and filing mechanics before relying on a deadline.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Cyprus
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Consultation closed; revised bill available

Situation in brief

The official consultation was published on 5 November 2025 and closed on 4 December 2025. Results and a revised bill are available. Article 36 proposes commencement on future Gazette publication; this clause does not establish that publication or commencement has occurred.

What applies now
  • Apply current Cypriot equality and labour law.
  • Do not claim transposition without a final official act.
Next deadline or monitoring point

Consultation is no longer open. Monitor the House of Representatives and Gazette for a final enacted measure and its actual commencement.

Employer actions
  • Use the proposal to prepare data; verify the House and Gazette record before changing contractual information or statutory dates.
  • Keep objective pay evidence.
  • Prepare EU recruitment, information and reporting readiness.
  • Update after primary-law review.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Malta
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

LN 173/2026 published; reporting timing needs careful application

Situation in brief

Malta published Legal Notice 173/2026 on 5 June 2026. Regulation 6 requires a written information response within eight days; requests in 2026 concern 2026 pay. Publication is established, but this review did not independently establish a commencement clause or exhaustively check later amendments.

What applies now
  • Use the official Maltese regulation and its actual commencement provisions.
  • Keep exact thresholds, sanctions and dates traceable to the regulation.
Next deadline or monitoring point

Regulation 9(2)–(4): first reports for 150+ by 7 June 2027 for 2026, and 100–149 by 7 June 2031 for 2030; annual for 250+, triennial for 100–249. Regulation 9(5) separately specifies fourteen working days after the relevant yearly period: confirm how both timing rules apply before filing.

Employer actions
  • Preserve the full 2026 payroll period and obtain written filing instructions resolving regulation 9(5) before submission.
  • Map the regulation's duties into recruitment and worker-information controls.
  • Prepare equal-value reporting data and approvals.
  • Retain the Legal Notice as the primary source for each claim.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Luxembourg
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Parliamentary discussion documented; enacted transposition not verified

Situation in brief

The Chamber of Deputies records Labour Committee discussion on 24 June 2026. The cited review does not verify comprehensive enacted transposition, but the committee record means a categorical pre-draft or no-bill description is not justified. The review is not an exhaustive search for later legislation.

What applies now
  • Apply current Luxembourg equality and employment law.
  • Wait for a final official transposition act before relying on new thresholds or dates.
Next deadline or monitoring point

Monitor the government, Chamber of Deputies and Legilux weekly. No employer threshold or commencement date is inferred from the committee meeting.

Employer actions
  • Prepare equal-value categories and a source-backed legal change register; await the final Legilux text for new obligations.
  • Preserve objective pay and consultation evidence.
  • Prepare EU-ready processes and multilingual communication.
  • Update after primary-law review.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

United Kingdom
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Great Britain 250+ gender-pay-gap reporting active

Situation in brief

The statutory regime described here covers England, Scotland and Wales, not the whole United Kingdom as one undifferentiated rule. Covered employers with 250 or more relevant employees report annually; private and voluntary-sector employers use a 5 April snapshot and publish by 4 April of the following year, while public authorities generally use 31 March and publish by 30 March.

What applies now
  • The 250+ Great Britain reporting duty is mandatory. Gender-pay-gap action plans are currently voluntary; the stated spring-2027 mandatory start is subject to legislation.
  • Determine coverage and the relevant employee count separately for Great Britain and Northern Ireland.
Next deadline or monitoring point

For the current Great Britain cycle, private and voluntary-sector employers publish by 4 April after the 5 April snapshot; covered public authorities publish by 30 March after the 31 March snapshot.

Employer actions
  • Keep the mandatory report calendar and prepare a separate action plan with owners, measurable actions and review dates. Label its present voluntary status.
  • Confirm legal entity, geography and 250-employee coverage.
  • Validate six statutory metrics and the written statement.
  • Publish on the government service and employer website by the applicable deadline.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

United States
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Federal equal-pay baseline plus state and local transparency rules

Situation in brief

The federal Equal Pay Act does not use an EU-style 100-worker reporting threshold. Title VII generally applies from 15 employees. EEO-1 demographic reporting generally covers employers with 100 or more employees and qualifying federal contractors with 50 or more employees and a qualifying contract; it is not a universal pay-gap report.

What applies now
  • California requires an in-post pay scale for covered 15+ employers, including roles potentially filled remotely in California. Its 100+ pay-data reports are separate from federal EEO-1. This is not a complete state-by-state survey.
  • Apply the Equal Pay Act and Title VII alongside state and local salary-range, pay-history and recordkeeping rules.
Next deadline or monitoring point

Use the EEOC's live EEO-1 cycle notice for the filing window; a July 2026 rescission proposal is not final law.

Employer actions
  • Check recruiter and agency adverts, California remote eligibility, and payroll/labour-contractor report scope; retain the certified submission receipt.
  • Map work locations and recruitment reach to state and local rules.
  • Separate EEO-1 demographic reporting from pay-equity analysis.
  • Preserve objective compensation evidence and privilege strategy with US counsel.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Australia
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

WGEA 100+ reporting active; 500+ target duties also apply

Situation in brief

Relevant Australian employers with 100 or more employees report annually to WGEA. A continuing-employer rule can keep an employer in scope while it remains at 80 or more employees, and employers with 500 or more employees have additional gender-equality target duties.

What applies now
  • WGEA reporting requires CEO sign-off and sharing specified reports. Directly employing relevant employers with 500+ workers also choose three gender-equality targets and have three years to meet them or demonstrate improvement.
  • Relevant private-sector and Commonwealth public-sector employers with 100 or more employees report to WGEA.
Next deadline or monitoring point

The next standard WGEA reporting window is 1 April to 31 May 2027; confirm any extension or entity-specific notice in the WGEA portal.

Employer actions
  • Keep CEO approval, governing-body delivery evidence and a three-target register with baselines, owners and the entity’s selection date.
  • Confirm relevant-employer and continuing-employer status.
  • Reconcile workforce and remuneration data before the portal opens.
  • For 500+ employers, document the required targets and progress evidence.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Canada
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Federal 10+ proactive pay equity and separate 100+ LEEP reporting active

Situation in brief

In federally regulated Canada, the Pay Equity Act generally applies from 10 employees and requires a proactive pay-equity process. The Legislated Employment Equity Program is a separate annual reporting layer generally for covered private-sector employers with 100 or more employees; provincial regimes must be assessed separately.

What applies now
  • The federal regime generally covers federally regulated employers with 10 or more employees, with process differences by size and bargaining status.
  • A federal conclusion must not be applied automatically to a provincially regulated employer.
Next deadline or monitoring point

For employers on the standard federal cycle, confirm the Pay Equity annual statement due 30 June 2027, LEEP reporting due 1 June 2027 and the employer-specific five-year plan update, including 4 September 2029 where applicable.

Employer actions
  • Record why the entity is federally regulated, the date it became subject, the plan’s due date and the next five-year update; keep LEEP separate.
  • Separate Pay Equity Act work from LEEP and provincial obligations.
  • Confirm the employer's posting, annual-statement and plan-update dates.
  • Maintain job classes, predominantly female/male comparisons and compensation adjustments with evidence.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Brazil
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

100+ semi-annual reporting active; sixth-report availability not confirmed

Situation in brief

Law 14,611/2023 requires semi-annual transparency reporting by private legal entities with 100+ employees, with anonymisation and mitigation measures. The sixth-report data-update window ran from 3 to 31 August 2026. As of the 11 September public-source review, MTE's main page still referred to the fifth report; availability of the sixth report in an authenticated employer account was not verified.

What applies now
  • Employers in scope participate in the official semi-annual data and publication cycle.
  • CBO occupational coding supports reporting context but does not replace objective job-value analysis.
Next deadline or monitoring point

The statutory publication cycle includes September. Retrieve and validate the sixth report when officially available; no precise September availability date was established by the reviewed public sources.

Employer actions
  • Check the employer’s official portal for its report, validate the figures and prepare the required publication; retain evidence of availability and the published report.
  • Confirm legal-entity headcount and that the August data submission was completed.
  • Retrieve and validate the government report when available and prepare a defensible explanatory action plan where needed.
  • Publish and retain the report and evidence in the prescribed September window.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Japan
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Gender wage-gap disclosure applies to 101+ regular workers from 1 April 2026

Situation in brief

From 1 April 2026, employers with 101+ regular workers must disclose the gender wage gap and the proportion of women in management. Employers with 101–300 add at least one other required indicator; 301+ add at least one from each of the two designated categories. The first covered financial year ends on or after 1 April 2026; publication is generally around three months after the next financial year begins.

What applies now
  • Employers with at least 101 regular workers are within the expanded disclosure scope, subject to the official definitions.
  • The published aggregate gap is not a substitute for equal-value job analysis.
Next deadline or monitoring point

Generally about three months after the following financial year begins. A June 2026 year-end points to approximately September 2026, not a universal 30 September deadline.

Employer actions
  • Prepare both indicators and the size-appropriate additional item(s). Record the first financial year ending on/after 1 April 2026 and the publication date.
  • Confirm the regular-worker count and fiscal year.
  • Calculate the prescribed female-to-male wage ratio and required contextual disclosures.
  • Publish in the required channel and retain calculation evidence.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

South Korea
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Equal-value pay applies under the Act; the old under-five-worker exemption was deleted

Situation in brief

Article 8 of the Equal Employment Opportunity and Work-Family Balance Assistance Act requires equal pay for work of equal value within the same business. The former under-five-worker exception in Enforcement Decree article 2(2) was deleted in 2018. Check the remaining specific exceptions, including cohabiting-relative-only businesses and domestic workers, against the authoritative Korean text.

What applies now
  • Equal-value comparison covers skills, effort, responsibility and working conditions.
  • The deleted five-worker exemption cannot be used to exclude small establishments.
Next deadline or monitoring point

Correct scope now; no universal public-report filing date follows from article 8.

Employer actions
  • Review small establishments previously excluded by the tracker. Compare actual skill, effort, responsibility and working conditions within the business.
  • Confirm any specific statutory exception with Korean counsel.
  • Retain actual job-content evidence and objective reasons for pay differences.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Israel
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Annual reporting active for 519+ employers and specified entities

Situation in brief

Israel's Equal Pay law requires annual gender-pay-gap analysis and publication for employers with more than 518 employees and for specified bodies covered by the amendment. Coverage is not a universal private-employer rule and must be tested by entity type. The current-year deadline and any extension remain unverified in this review.

What applies now
  • In-scope large employers prepare both detailed internal information and a public-facing report.
  • Confidentiality and worker-group design require legal and data-protection control.
Next deadline or monitoring point

Current-cycle publication deadline and any extension: verification required.

Employer actions
  • Obtain the Commission’s current notice for the covered year before deciding whether the report is late; preserve internal and public reports with privacy controls.
  • Confirm whether headcount or specified-body coverage applies.
  • Calculate employee-level and public aggregate outputs with privacy controls.
  • Publish and provide required information within the annual cycle.
Legal review
2026-09-19
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

South Africa
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

2026 EEA2/EEA4 reporting open for designated employers

Situation in brief

The live Department portal confirms the 2026 EEA2/EEA4 cycle is open. Listed designated employers include those with 50+ employees, organs of state and employers with 1–49 employees designated by collective agreement. This is a fresh operational review; the 2025 regulations were not reread successfully in this pass.

What applies now
  • The live 2026 portal accepts EEA2 and EEA4 only, not EEA12/13. It requires CEO approval and an acknowledgement of receipt; no amendment is allowed after final submission.
  • EEA4 income-differential information is a regulatory submission, not a public EU-style pay-gap report.
Next deadline or monitoring point

Manual filing closes 1 October 2026; online filing closes 15 January 2027 at 23:59. The separate 31 August EEA14 notice concerns closure, merger, liquidation or cessation and is not the EEA2/EEA4 deadline.

Employer actions
  • Use a pre-submission checklist for figures and CEO approval, then save the acknowledgement. Select online or manual delivery deliberately.
  • Confirm designated-employer status under the amended rules.
  • Reconcile EEA2/EEA4 workforce, occupational-level and income data.
  • Select the filing channel and meet its distinct closing date.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

India
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Code on Wages section 3 in force; no universal public reporting

Situation in brief

Section 3 of India's Code on Wages commenced on 21 November 2025 and prohibits gender discrimination in wages for the same or similar work and in recruitment, subject to statutory exceptions. It has no general headcount threshold and does not create a universal public employer pay-gap report.

What applies now
  • The official explanation explicitly includes transgender identity in section 3 gender-discrimination controls for wages and recruitment. A generic male/female-only policy misses that scope.
  • Maintain non-discriminatory wage and recruitment controls under the law in force.
Next deadline or monitoring point

No universal filing date is asserted; monitor India Code, Gazette and implementing rules for changes.

Employer actions
  • Review recruitment templates and wage-comparison controls for gender-inclusive application; confirm the appropriate central/state rules for the establishment.
  • Apply section 3 without importing an EU headcount threshold.
  • Document same-or-similar-work comparisons and objective wage reasons.
  • Check sector, state and recruitment restrictions before implementation.
Legal review
2026-09-19
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Singapore
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Tripartite fair-employment guidance active; Workplace Fairness Act enacted but not yet in force

Situation in brief

Singapore's current employer baseline remains the applicable fair-employment and tripartite framework. The Workplace Fairness Act has been enacted and is targeted to take effect at end-2027. A future exemption for employers with fewer than 25 employees has been announced, but those future statutory provisions are not yet operative. No universal public pay-gap report applies.

What applies now
  • Apply current fair-employment, non-discrimination and tripartite requirements relevant to the employer.
  • Do not convert a national statistic into a company reporting duty.
Next deadline or monitoring point

Monitor MOM for commencement and implementing rules toward the end-2027 target; no current universal filing date is asserted.

Employer actions
  • Review recruitment criteria and grievance handling now; keep an owner for the final commencement notice and implementation rules.
  • Apply current tripartite fair-employment practices now.
  • Treat the future under-25 exemption and statutory processes as planning assumptions only until commencement.
  • Maintain objective pay criteria and internal gap monitoring.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Switzerland
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

100+ headcount equal-pay analysis framework active through 30 June 2032

Situation in brief

The Swiss threshold is 100 employees by headcount, not full-time equivalents, and apprentices are excluded. Analysis, independent verification and employee communication are separate steps. A repeat after four years is required only when the prior analysis did not demonstrate equal pay; the statutory framework is time-limited through 30 June 2032.

What applies now
  • Use the federal rules and an accepted analytical method such as the official Logib tool where applicable.
  • Confirm exemptions and the ten-year statutory time window before concluding scope.
Next deadline or monitoring point

Derive the date from first coverage or the last failed analysis; framework runs through 30 June 2032.

Employer actions
  • Record the last analysis result, workforce at the year start, independent-review evidence and next required date; do not copy another employer’s 2025–2027 sequence.
  • Test the threshold using headcount and exclude apprentices correctly.
  • Confirm whether a prior successful analysis removes the repeat requirement.
  • Schedule analysis, independent verification and communication as separate controlled milestones.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Iceland
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

National 50+ reporting framework in force; transition depends on prior certification

Situation in brief

Law 53/2026 and consolidated Law 150/2020 establish reporting every three years for entities averaging at least 50 staff annually. Regulation 946/2026 and regulator guidance were read on 13 September: submit job classification, sex-disaggregated pay analysis and a remediation plan where applicable. The earlier EEA-incorporation observation remains dated 3 September and was not reverified.

What applies now
  • Manage the transition from the former certification/confirmation regime to the new statutory framework.
  • The earlier EEA-incorporation observation is dated 3 September 2026 and was not reverified; confirm the current EEA record separately from Iceland's national law.
Next deadline or monitoring point

Article 9 of Law 53/2026: previous certification or confirmation holders submit three years after their latest certification or confirmation. Covered entities that obtained neither must submit before 1 March 2027.

Employer actions
  • Locate the latest certificate or confirmation and approval of the equality plan; calculate the entity’s deadline from that evidence.
  • Determine 50+ coverage under the new definitions.
  • Preserve evidence of the latest certification or confirmation and calculate the first report date three years after that event; covered entities with neither must report before 1 March 2027.
  • Set a three-year reporting calendar and validate the first-report date in the regulator portal.
  • Have an equality plan approved by Jafnréttisstofa before submitting the reporting data, as required by the regulator guidance.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

New Zealand
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Amended equal-pay and pay-equity claim process active; no universal public report

Situation in brief

New Zealand's amended Equal Pay Act requires the current pay-equity claim eligibility and response process. Before a claim proceeds to pay-equity assessment, the employer must determine whether it meets the circumstances and requirements and has merit. Merit requires work performed by a workforce that has been at least 70% female over the past ten consecutive years, and reasonable grounds to believe the work was historically undervalued and remains subject to systemic sex-based undervaluation. Acknowledge receipt within five working days; decide within 60 working days, with a reasoned limited extension where allowed.

What applies now
  • Current guidance uses a merit-and-requirements assessment, not the older arguability wording. Acknowledge within five working days; decide within 60 working days, with a reasoned limited extension where allowed.
  • Apply the current claim process and any 2025 amendments in the consolidated Act.
Next deadline or monitoring point

5 working days to acknowledge; 60 working days to decide. Extension: up to 20 working days for one employer, 80 for multiple employers, subject to the guidance conditions.

Employer actions
  • Create a receipt-date log, acknowledgement template, union-notification privacy check and decision calendar; obtain legal review before discontinuing a claim.
  • Maintain a controlled intake and response process for claims.
  • Test current statutory eligibility rather than an obsolete pre-amendment standard.
  • Protect lawful pay discussions and document objective job-value evidence.
Legal review
2026-09-19
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Peru
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Job-category and equal-value pay framework active without a general headcount threshold

Situation in brief

Law 30,709 requires salary-policy controls and job-category/function schedules supporting non-discriminatory remuneration. The official Congress explanation also requires informing workers of the salary policy. The previously stated 4 August 2026 Supreme Court development could not be substantiated and is withdrawn; it must not be relied on as legal evidence.

What applies now
  • Maintain objective category/function schedules and communicate the salary policy to workers.
  • No new court holding or general public-report deadline is established by the reviewed source.
Next deadline or monitoring point

Maintain the existing controls now; no new court-created deadline is asserted.

Employer actions
  • Keep approved category/function schedules and evidence that workers received the salary policy. Obtain the actual judgment before using any case-law claim in a pay decision.
  • Keep objective explanations for remuneration differences.
  • Verify later amendments and judgments from their actual texts before reliance.
Legal review
2026-09-19
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
Medium

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Chile
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Same-work pay rule active; 10+ complaint procedure and 200+ role register

Situation in brief

Chile's statutory rule addresses equal remuneration for the same work and should not be described as a general equal-value regime. Employers with 10 or more workers require the applicable internal complaint procedure with a written response within 30 days; employers with 200 or more workers must maintain the prescribed register of positions or functions. No universal public pay-gap report applies.

What applies now
  • Apply the equal-remuneration rule and relevant internal complaint procedures.
  • Do not import EU reporting thresholds into Chile.
Next deadline or monitoring point

No universal filing date is asserted; ensure any complaint receives the required written response within 30 days.

Employer actions
  • Check the internal regulations and who receives a pay complaint; ensure the response explains the objective basis and is retained.
  • Apply the statutory same-work test accurately and document objective exceptions.
  • For 10+, maintain the complaint procedure and 30-day response control.
  • For 200+, maintain the required role or function register.
Legal review
2026-10-08
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.

Argentina
Key risks
  • Incorrect scope, stale sources or unsupported pay explanations can increase back-pay, compensation, penalty, litigation, employee-relations and reputation exposure.
  • Country applicability, collective-agreement effects and current consolidated law must be confirmed for the employer before a material decision.
ACLASA methodology

ACLASA uses one 1,200-point analytical core with 4 factors, 14 subfactors and bands B01-B15. Evaluate the actual work first. Keep the equal-value category, ACLASA band, ISCO/other occupational code, collective classification and pay range as separate controlled fields.

Legal-use caveat

Operational compliance aid, not employer-specific legal advice or a guarantee of litigation outcome. Use the cited official source and obtain local review before implementation or reliance.

Legislative stage

Equal-remuneration baseline; separate confidential social balance for more than 300 workers

Situation in brief

The equal-remuneration baseline is separate from Law 25,877 articles 25–27. The latter require an annual confidential social balance for employers with more than 300 workers (301+), not 300 or more. Delivery to the relevant union is within 30 days of preparation, with a confidential copy to the labour authority.

What applies now
  • Apply equal-remuneration, non-discrimination and collective-agreement rules relevant to the employer.
  • Do not present an equality programme as a mandatory reporting statute.
Next deadline or monitoring point

Annual balance; union delivery within 30 days after preparation. Article 27 governs first application after reaching the statutory size.

Employer actions
  • Recheck entities with exactly 300 workers. For covered employers, assign preparation, union delivery and confidential authority-copy responsibilities.
  • Apply the equal-value principle without an invented general size threshold.
  • Retain the annual preparation date, union receipt and confidential authority copy.
Legal review
2026-09-19
Source access checked
2026-10-08
Next scheduled review
2026-10-09
Confidence
High

Official sources

This translated presentation preserves the official sources and review dates. Qualified language and local legal review remain pending.