Pay transparency: EU deadlines and preparing HR data

Directive (EU) 2023/970 strengthens equal pay for equal work or work of equal value. Article 34 required Member States to adopt transposition measures by 7 June 2026. That date alone does not prove that a specific rule is already in force in Slovak law. Before acting, check current legislation, transitional provisions, the competent authority, and guidance for your type of employer.

The Directive also covers information for applicants. An employer must communicate the initial pay or a pay range in the vacancy notice or before the interview. It also restricts questions about pay history. Domestic rules may determine the practical form, so do not copy a process from another country without checking it.

Article 9 sets the reporting timetable. Employers with 250 or more workers first report by 7 June 2027 and then annually. Employers with 150 to 249 workers first report by the same date and then every three years. Employers with 100 to 149 workers first report by 7 June 2031 and then every three years. National law may also address smaller employers.

Article 7 gives workers the right to request written information about their own pay and average pay by sex in a comparable work category. The Directive sets a response deadline of two months. Record the request, deadline, and authorised recipient. Check the protection of identifiable colleagues in small groups.

Preparation does not have to begin with a new HR system. First map the sources of base pay, bonuses, and benefits, comparable work categories, data owners, and change approval. Comparison criteria should be objective and gender-neutral. A useful export includes a worker identifier, work category, period, pay components, and their source. Process sex data only where you have a lawful basis.

A system may need access roles, change history, dated snapshots, and checks for missing values. This is not a mandatory feature list or legal advice. It is a repeatable way to prepare data for review. Confirm minimisation, retention, and access controls for personal data.

Do not classify every AI tool in HR the same way. Its intended purpose and effect on people matter. Read our article on AI in employment and see our technology audit service for technical preparation.