New Pay Transparency Rules: Employers Must Reassess Pay Systems Already in 2026

On 7 June 2026, Act No. 76/2026 Coll. on Equal Pay for Men and Women for Equal Work or Work of Equal Value (the “Act”) will enter into force, transposing Directive (EU) 2023/970 of the European Parliament and of the Council on pay transparency into Slovak law. The new legislation introduces significant changes in the areas of remuneration, pay transparency, recruitment processes and employment compliance.

For employers, this will not merely represent another administrative obligation. The Act establishes a new framework for internal remuneration systems, strengthens employees’ procedural rights and, at the same time, significantly increases employment and litigation risks in cases of unjustified pay disparities.

Below is an overview of the most significant changes that the new legislation will bring to employment practice.

What changes does the new legislation introduce?

One of the most significant changes is the obligation for every employer to implement a transparent remuneration structure based on objective and gender-neutral criteria, enabling an assessment of whether employees perform equal work or work of equal value. Remuneration criteria must, in particular, take into account the complexity of work, level of responsibility, effort, working conditions and relevant skills, including communication and interpersonal abilities (soft skills). In practice, employers will need to reassess existing remuneration systems, internal salary-setting methodologies, as well as the transparency of the criteria on the basis of which remuneration is granted or increased.

For employers existing as of the effective date of the Act, the short implementation timeline will be particularly important. The new rules must be implemented no later than 31 July 2026. , leaving employers only limited time to prepare internal processes and documentation.

The new rules will also significantly affect recruitment processes. Upon the Act entering into force, employers will be required to ensure that:

a. job advertisements and job titles are gender-neutral,

b. selection processes are non-discriminatory,

c. candidates receive information regarding starting remuneration or the applicable salary range before the job interview or conclusion of the employment contract, and

d. employers do not request information regarding a candidate’s current or previous remuneration.

In practice, this means reassessing recruitment processes, HR documentation, job advertisements and internal salary bands.

The new regulation will also affect existing employment relationships. Employees will gain the right to request information regarding:

a. their individual level of remuneration, and

b. the average remuneration level by gender within a comparable category of employees performing equal work or work of equal value.

Employers will be required to provide such information within two months, while the Act expressly provides that confidentiality clauses concerning remuneration will be unenforceable if they prevent employees from disclosing information about their own pay.

Pay transparency obligations will not apply solely in the relationship between employer and employee. The Act also introduces an obligation to regularly report the gender pay gap to the Slovak Ministry of Labour, Social Affairs and Family.

The scope of reporting obligations will depend on the size of the employer:

a. employers with 100 to 249 employees will be required to submit reports every three years,

b. employers with 250 or more employees will be subject to annual reporting obligations.

The initial reporting periods will also vary depending on employer size:

a. employers with at least 150 employees must submit their first report by 7 June 2027,

b. employers with 100 to 149 employees must submit their first report in 2031.

Reporting will not merely constitute a formal administrative obligation. If an unjustified pay difference of at least 5% is identified within a particular category of employees and is not remedied within six months, the employer will be required to carry out a joint pay assessment together with employee representatives. Such assessment will include a detailed analysis of pay disparities, the causes of inequalities and the implementation of specific remedial measures.

Zvýšené sporové a sankčné riziko

The new legislation will also significantly strengthen the enforceability of the right to equal pay.

The Act introduces:

a. the right to claim compensation for unpaid remuneration, non-material damage and other losses,

b. a three-year subjective limitation period, and

c. a stricter burden of proof for employers, who may in certain cases be required to demonstrate that discrimination has not occurred.

In addition to private law claims, employers should also consider regulatory risks, as non-compliance with reporting obligations may result in fines ranging from EUR 4,000 to EUR 8,000.

What should employers do now?

Given the short implementation period, we recommend starting preparations without delay, in particular by:

a. conducting a gender pay gap assessment and identifying high-risk employee categories,

b. reviewing the compliance of existing remuneration systems with the requirement for objective and non-discriminatory criteria,

c. preparing or updating a transparent remuneration structure and internal remuneration rules, including the relevant internal policy, ,

d. implementing or updating salary bands and the job grading framework,

e. revising job advertisements, recruitment processes and HR documentation,

f. implementing internal procedures for handling employee requests concerning remuneration information, and

g. assessing organisational readiness for future reporting obligations and preparing documentation for potential employment disputes.

Conclusion

The Act represents one of the most significant employment law developments in recent years and will have a practical impact on a broad range of employers. Compliance will not simply involve meeting a new statutory obligation, but rather reassessing remuneration systems, recruitment processes, internal documentation and broader employment compliance arrangements.

Given the scope of the changes, new reporting obligations, enhanced employee rights and potential litigation risks, employers should begin assessing their level of preparedness well in advance. Early identification of risk areas and the implementation of transparent, objective and defensible remuneration rules will be essential for the smooth implementation of the new legal framework.

Should you require assistance, we would be pleased to provide tailored advice or comprehensive legal support in assessing organisational readiness, implementing internal processes, reviewing HR documentation and practically implementing the requirements of the new legislation.