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The Pay Transparency Directive has been adopted at the EU level, but it is not yet in force in Finland. It is now clear that Finland will not be implementing the Directive by the original deadline of 7 June 2026.
The Finnish government proposal for the necessary national legislative amendments has been under preparation for a considerable time, and the publication of the final proposal has been postponed several times. According to the most recent information, the final government proposal is expected to be published in mid‑June 2026. As a result, the actual implementation of the Pay Transparency Directive is likely to be delayed until autumn 2026, or possibly even early 2027.
Similar developments have been reported in other EU Member States. For example, the Swedish government has announced that Sweden will not be implementing the Directive and has called for renegotiations at the EU level, with the aim of simplifying the substance and requirements of the Directive. Comparable signals have been reported from Estonia.
Despite the delayed implementation of the Directive in Finland, it is important to note that the current national legislation already imposes several obligations on employers concerning pay transparency and equal pay. Under the Finnish Act on Equality between Women and Men, companies employing at least 30 employees are required to carry out a pay survey as part of their mandatory equality plan. The purpose of the pay survey is to identify and eliminate any unjustified pay differences between women and men performing the same or similar work of equal value. If the pay survey reveals unjustified pay disparities, the employer must take corrective measures to address them.
While the implementation of the Pay Transparency Directive continues to be delayed, employers operating in Finland with at least 30 employees are advised to ensure in the meantime that their statutory equality plan, including the pay survey, is up to date and complies with the applicable legal requirements. The equality plan, including the pay survey, must be updated at least every two years in cooperation with employee representatives.
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