Slovakia Becomes First EU State to Fully Transpose the Pay Transparency Directive

By Brittany Dian-Hansell

BLOG OVERVIEW: On April 15, 2026, Slovakia became the first EU Member State to fully transpose the EU Pay Transparency Directive (2023/970), adopting the Equal Pay Act with an entry-into-force date of June 7, 2026, the exact EU transposition deadline. While the Act closely mirrors the Directive's minimum standards, it introduces several notable expansions. Employers with operations in Slovakia must implement compliant pay structures by July 31, 2026, and those with 150 or more employees face an initial reporting period covering August 1 through December 31, 2026, with fines reaching up to €100,000 under expanded Labour Inspectorate enforcement powers. 

Slovakia has made history in the implementation of the European Union Pay Transparency Directive (the Directive). On April 15, 2026, Slovakia’s National Council adopted the Equal Pay Act becoming the first, and to date, only EU Member State to fully transpose the Directive into national law ahead of the EU-wide deadline. The law enters into force on June 7, 2026, the exact date of the Directive’s transposition deadline, making Slovakia’s achievement all the more notable as the majority of other member states remain in various stages of drafting or consultation.

While the Equal Pay Act largely delivers on Slovakia’s commitment to transposing the Directive closely, there are several notable elements and a few meaningful deviations that employers with employees in Slovakia should be aware of.

Close Alignment with the EUPTD Minimums in Key Areas

Slovakia’s Equal Pay Act aligns closely with the Directive’s minimum standards, including a definition of remuneration that covers base pay plus any additional monetary or non-monetary benefits, pay structures that enable assessment of equal work or work of equal value using objective criteria, key provisions on pay transparency before the interview or contract signing, pay criteria accessibility, employee right to pay information, and phased pay reporting requirements including joint pay assessments for unjustified pay gaps that exceed 5%. Where an employer has breached the Act's transparency or reporting obligations, the burden of proof shifts to the employer to show no discrimination occurred, unless the breach was clearly unintentional and minor.

Where Slovakia Goes Beyond the Directive

While Slovakia’s approach is broadly faithful to the Directive’s text, employers should be aware of several areas where the Equal Pay Act goes further than the Directive’s minimum standards:

• Same-sex equal pay protections: One of the most significant departures from the Directive is Slovakia’s extension of equal pay protections beyond male-female comparisons. The Act explicitly amends the Labour Code (Act No. 311/2001) to provide that employees of the same sex performing equal work or work of equal value also have the right to equal pay.
• Job evaluation criteria: Slovakia’s Act explicitly requires that objective job evaluation criteria account for soft skills, specifically social and communication abilities, going beyond the Directive’s more general reference to skills and effort. Where employee representatives exist, criteria must be agreed with them.
• Right to information appears in two phases: Employees may request written information about their own pay level once the Act takes effect, which aligns with the Directive directly. It is important to call out that the Act explicitly notes that average pay levels broken down by sex for an individual’s employee category shall be provided by employers for the first time in the year 2027, indicating a phased approach.
• Response deadlines for clarifications: Employers must respond within two months to an employee’s initial request for pay information and provide a substantive response to employees within 30 days of any follow-up clarification requests.
• Scope includes judges and prosecutors: The Act expressly covers judges (with the court as employer) and prosecutors (with the service office as employer), extending equal pay obligations into the judiciary.
• Cross-employer and hypothetical comparators: Employees may compare themselves with employees at different employers where pay conditions share a single source, and comparisons are not limited to concurrent employment. Where no actual comparator exists, the assessment may be carried out by comparing how the employee would have been treated in a comparable situation.
• Intersectional discrimination: The Act's definition of discrimination expressly includes intersectional discrimination (i.e., sex-based discrimination combined with another protected ground), thereby ensuring compounding disadvantages are actionable.

Reporting Timeline

Slovakia’s reporting timeline follows the phased approach set out in the Directive, but with a country-specific annual filing deadline of April 15 (rather than the Directive’s default of June 7) for ongoing reports after the initial submission.

One critical operational detail from the Act’s transitional provisions (§ 18)? The first reports for employers with 150 or more employees will cover only the period from August 1 through December 31, 2026, not a full calendar year. This shortened initial window reflects the law’s entry into force on June 7, 2026, and the July 31, 2026, deadline for compliant pay structures.

Penalties

Employers who fail to submit a required pay report will receive a remediation notice from the Ministry of Labour with at least 15 days to comply. Continued non-compliance attracts a fine of €4,000–€8,000, based on the seriousness, duration, consequences, circumstances, and recurrence of the offence. Fines must be imposed within two years of the violation. Beyond pay reporting, the Act extends the Labour Inspectorate's enforcement powers to cover all employer obligations under the Act, and fines could reach up to €100,000. Slovakia did not include any specific provision regarding repeat offenses.

How Should Employers Prepare?

The operational impact of the Equal Pay Act is substantial, and the window for preparation is short. As with the Directive broadly, employers should ensure recruitment processes are updated in accordance with key pre-employment pay transparency provisions. Compliant pay structures must be in place by July 31, 2026 (§ 18(1)) and built on objective, sex-neutral job evaluation criteria covering complexity, responsibility, demands, working conditions, and soft skills. Internal pay information systems should be built before the employee right to information requirements take effect, including processes to identify employee categories, calculate required metrics, and meet statutory response deadlines. Finally, employers should proactively audit pay gaps, including among employees of the same sex, to prepare for Slovakia's expanded equal pay protections ahead of the first reporting period.

As we approach the transposition deadline of June 7 in the coming weeks, the European compliance landscape will continue to shift rapidly. DCI will continue to monitor developments and provide updates as they occur. Sign up to receive our monthly EU Pay Transparency Directive newsletter.