What does the directive change in recruitment?

An applicant has the right to receive the initial pay or its range for the position before pay negotiations, for instance in the job advertisement or before the interview, and where relevant the applicable collective agreement provisions. The employer may not ask the applicant's current or previous pay. Advertisements and job titles must be gender-neutral and the recruitment process non-discriminatory.

What information may an employee request about their pay?

In writing, information on their individual pay level and on average pay levels broken down by sex for the categories of workers doing the same work or work of equal value. The employer must respond within a reasonable time and at most two months, remind employees of the right every year, and may not prevent employees from disclosing their pay to enforce equal pay. The directive does not make anyone's individual pay public.

Is the law already in force in Finland?

The directive had to be transposed by 7 June 2026. In Finland the government submitted a bill on 9 July 2026 amending the Equality Act and related acts, and the amendments are intended to take effect on 1 January 2027. The directive's obligations are addressed to the Member State: a private employer is bound as law only by the national provisions, but sufficiently precise provisions of the directive can be invoked against a public employer once the deadline has passed. The principle of equal pay and the Equality Act's existing pay survey duty for employers with at least 30 employees are in force now.

The Pay Transparency Directive: what an employer must do and when Finnish law takes effect

Q: Who must report pay gaps, and when?

Under the directive, employers with at least 250 workers report annually and those with 150 to 249 workers every three years, the first time by 7 June 2027; employers with 100 to 149 workers report every three years from 7 June 2031. Under the Finnish government bill, employers regularly employing at least 100 people would report the data to the Ombudsman for Equality through the Incomes Register and Statistics Finland. A joint pay assessment is carried out if the average pay gap in any category is at least 5 percent, has not been justified objectively and has not been corrected within six months.

Pay information before negotiation, no pay history questions, a right to average pay data and pay gap reporting from 100 employees. The Finnish act is due on 1 January 2027.

In brief

The Pay Transparency Directive (EU) 2023/970 obliges employers to disclose pay before recruitment, to give employees information on average pay levels by sex, to report gender pay gaps from a threshold of 100 workers and to correct unjustified gaps. Member States had to transpose it by 7 June 2026. In Finland the government submitted a bill amending the Equality Act on 9 July 2026, and the amendments are intended to take effect on 1 January 2027. The directive does not make anyone's pay public and does not require paying everyone the same; it requires that the grounds for pay are transparent and gender-neutral and that an employee can compare their pay with the average of those doing the same work.

Recruitment: a pay range and a ban on asking

Article 5 of the directive concerns the time before employment. An applicant has the right to receive from the prospective employer information on the initial pay or its range for the position, based on objective, gender-neutral criteria, and where applicable the relevant provisions of the collective agreement. The information must be provided so as to ensure an informed and transparent pay negotiation, for example by publishing it in the vacancy notice or before the interview.

Paragraph 2 prohibits the employer from asking applicants about their pay history in current or previous employment. The question "what is your salary expectation relative to your current pay" leaves the interview form. Paragraph 3 requires that vacancy notices and job titles are gender-neutral and the recruitment process non-discriminatory. Under the Finnish government bill the employer would have to ensure a transparent pay negotiation by giving information on the initial pay or its range in good time.

For a recruiting supervisor this is two changes: the applicant receives the pay or its range before pay negotiations, most commonly in the advertisement already, and the interview does not ask about previous pay. What else may be asked of an applicant is covered in A supervisor's data protection duty.

In employment: the right to information

Article 7 gives the employee the right to request and receive in writing information on their individual pay level and on the average pay levels, broken down by sex, for the categories of workers doing the same work or work of equal value. The request may also be made through workers' representatives or an equality body, and where the information is inaccurate or incomplete the employee may ask for reasonable clarifications and receive a substantiated reply.

Under paragraph 3 the employer must inform all workers annually of this right and of how to exercise it, and under paragraph 4 provide the information within a reasonable time and in any event within two months of the request. Paragraph 5 prohibits preventing workers from disclosing their pay to enforce equal pay, and Member States must prohibit contractual terms that do so. A pay secrecy clause in an employment contract therefore no longer holds. Paragraph 6 allows the employer to require that information other than one's own pay is used only to exercise the right to equal pay.

According to the ministry's FAQ the directive does not affect the confidentiality of individual pay: nobody has to reveal their own pay to a colleague, but the average pay level of those doing the same or equal work is available. In addition, an employer with at least 50 employees would have to provide information on the criteria it uses to determine pay progression.

Reporting and the joint pay assessment

Article 9 obliges employers to report gender pay gaps: the mean pay gap, the median pay gap, the gaps in complementary and variable components, the proportion of female and male workers in each quartile pay band, and the pay gap by category of workers.

Employer size	Reporting frequency	First report by
At least 250 workers	Every year	7 June 2027
150 to 249 workers	Every three years	7 June 2027
100 to 149 workers	Every three years	7 June 2031
Under 100 workers	Voluntary; a Member State may require it	—

The data is submitted to an authority, and the pay gaps by category are given to all workers and their representatives. Management must confirm the accuracy of the data after consulting workers' representatives. Where a pay gap cannot be justified by objective, gender-neutral criteria, the employer must remedy the situation within a reasonable time in cooperation with the representatives and the authorities.

Article 10 adds the joint pay assessment: it must be carried out with workers' representatives when the reporting shows an average pay gap of at least 5 percent in any category of workers, the employer has not justified it objectively and has not corrected it within six months of submitting the report. The assessment covers the proportion of women and men in each category, average pay levels, the gaps and their reasons, measures to correct the gaps and an evaluation of earlier measures, and it is submitted to the monitoring body.

Under the Finnish government bill, employers regularly employing at least 100 people would report the data to the Ombudsman for Equality through the Incomes Register and Statistics Finland, failing to carry out a joint pay assessment would carry a penalty payment, and the time limit for pay discrimination compensation claims would be extended to three years.

Data protection in pay data

Pay is personal data, and Article 12 of the directive says so directly: information provided under Articles 7, 9 and 10 is given in accordance with the GDPR and may not be used for any purpose other than applying the principle of equal pay. Where disclosure would reveal an identifiable worker's pay directly or indirectly, a Member State may limit access to workers' representatives, the labour inspectorate or the equality body, who advise the worker without disclosing individual pay.

For HR this means that an average for a small group is a risk: the average of a group of three reveals an individual's pay. Answering an information request therefore requires both the calculation and a data protection judgement, and that is exactly the edge case the library course rehearses.

What is already in force and what is coming

The principle of equal pay is not new. The Equality Act (609/1986) prohibits pay discrimination based on gender, and according to the ministry its pay survey duty already applies to employers regularly employing at least 30 people. The directive does not change the principle but makes it verifiable: pay information for applicants before negotiation, the right to average pay data, the report and the assessment are the instruments by which discrimination becomes visible.

The transposition deadline under Article 34 was 7 June 2026. In Finland the government bill was submitted on 9 July 2026, and the acts are intended to take effect on 1 January 2027. An employer therefore has time to prepare, but no reason to wait: recruitment templates, grouping of pay by criteria for work of equal value and a process for information requests are the same regardless of the law's final wording. How an obligation of this kind is shown to be met is covered in Training evidence for the regulator.