By Arsis Global Consulting · Executive Search & Business Advisory
The EU Pay Transparency Directive must be transposed into national law by 7 June 2026. In Hungary, Bulgaria, Greece, and Romania — all four of our core markets — that work is still unfinished. That is not a reason to wait. It is a reason to move.
The directive is binding regardless of whether a country’s national law is ready. Its core obligations — salary range disclosure in recruitment, the ban on asking candidates about previous pay, and employee rights to request pay comparison data — are clear enough to carry direct legal effect even before domestic legislation is enacted. Employers who assume uncertainty equals safety are misreading the situation.
Where each of our market stands on the EU Transparency Directive?
🇭🇺 Hungary
No implementing legislation published. Equal pay exists in principle but structured reporting, salary disclosure, and formal job evaluation are all new territory. Minimum transposition expected when law eventually arrives.
🇧🇬 Bulgaria
A draft amendment to the Anti-Discrimination Act exists but has not cleared parliament. Likely to miss the June deadline. Key detail: pay secrecy clauses in employment contracts become explicitly illegal — review yours now.
🇬🇷 Greece
A specialist committee was tasked with preparing the framework. No bill published. Existing anti-discrimination law provides a base, but pre-hire salary disclosure and pay gap reporting are entirely new obligations for Greek employers.
🇷🇴 Romania
General equal pay rules already in place, but the transparency framework is pending. A January 2027 entry into force is considered more realistic than June 2026. First reporting deadlines still apply from 2027 — based on 2026 payroll data.
Companies with 150 + employees must submit their first gender pay gap report by June 2027 — covering 2026 data. That collection window is already open. If your payroll systems cannot yet produce gender-disaggregated reports by job category, that is your most pressing action item.
What to do right now
FIVE PRIORITIES FOR EMPLOYERS ACROSS THE REGION
01 Audit your job architecture — can you define which roles are equivalent for comparison purposes?
02 Document your pay logic using objective, gender-neutral criteria that can withstand scrutiny
03 Remove salary history questions from recruitment templates immediately
04 Assess whether your payroll systems can produce gender pay gap reports — if not, fix that now
05 Review employment contracts for pay secrecy clauses and amend them before any law takes force
In our work across these four markets, we see a consistent pattern: the organizations preparing now are not just building compliance infrastructure. They are becoming more competitive in attracting senior talent. Candidates at the executive level are already asking about pay practices. Transparency, when it is real, is an employer brand asset.
Operating in Hungary, Bulgaria, Greece, or Romania? Let us help you think through what pay transparency means for your hiring strategy and compensation positioning. Talk to Us
