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Legal & Tax Alerts

Pay Transparency: A Structural Shift in How Remuneration Is Defined

Publication: ZRVP

A shift is underway in how remuneration is defined, justified and communicated in the workplace. 

On 30 March 2026, the Ministry of Labor, Family, Youth and Social Solidarity launched for public debate a draft law on salary transparency and the strengthening of the principle of equal pay between women and men for equal work or work of equal value, as well as for the amendment and supplementation of certain normative acts. 

The draft law aims to transpose Directive 2023/970 of the European Parliament and of the Council of 10 May 2023, which seeks to reinforce the application of the principle of equal pay through enhanced transparency and more effective compliance mechanisms.  

In its current form, the draft law contains several sensitive aspects which, if adopted without further clarification, may have a significant practical impact across the labour market. 

Below are some of the key implications that may arise: 

  1. A shiftfrom salary policies based primarily on individual negotiation to more formalized frameworks built on explicit, verifiable and gender-neutral criteria; 
  2. The need to revisit and align internal structures, includingjob descriptions, evaluation criteria, salary grids, as well as bonus and benefit systems; 
  3. Potential interpretative ambiguity surrounding the notion of“work of equal value”, which may lead to inconsistent application; 
  4. Transformation of salary into a contractual element subject to objective justification control when gender-related differences arise;
  5. Risksregardingpersonal data protection; 
  6. The need to update internal policies and contractual confidentiality clauses, as employeescan no longer berequired to keep their salary confidential; 
  7. A potential rise in employee requests for salary adjustments, including in situations where legal provisions may be misinterpreted or insufficiently clear;
  8. New reporting obligations for employers with at least 100 employees, including the periodic disclosure of gender pay gap data. 

In light of the above, if adopted in its current form, is likely to trigger a substantial restructuring of how remuneration is determined, documented and justified. This would have far-reaching consequences not only for employer practices, but also for the broader dynamics of employment relationships.  

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