October 3, 2025
Slovakia has now published their draft. Learn what it includes and prepare.
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In May 2023, the European Union adopted Directive (EU) 2023/970 on pay transparency to strengthen the principle of equal pay for women and men. The Directive requires Member States to introduce measures ensuring the right to equal pay for equal work or work of equal value through greater pay transparency and stronger financial remedies. The directive includes pay transparency for job applicants, transparency in pay structures and pay progression, employees' right to information about pay levels, regular reporting of gender pay gaps by larger employers, and joint pay assessments when significant pay gaps are found. The Directive also requires member nations to implement robust enforcement - for example, victims of pay discrimination must be able to claim full compensation (with no fixed upper limit) and the burden of proof shifts to the employer once a worker shows facts indicating possible pay discrimination. Member States have until 7 June 2026 to implement these requirements into national law.
Legislative Strategy: Slovakia is implementing the Directive through a new standalone law - the proposed "Zákon o transparentnosti v odmeňovaní" (English title: Law on the Application of the Principle of Equal Pay for Men and Women for Equal Work or Work of Equal Value, and on amendments of certain laws). Rather than simply amending the Labor Code, the government chose a comprehensive approach: introduce a dedicated pay transparency act and concurrently change related laws like the Labor Code, the Labor Inspection Act, and the Employment Services Act to ensure coherence with the EU requirements.
Timeline: The Ministry of Labor (MPSVR SR) published an initial policy intent (Predbežná informácia) in May 2025 and prepared the draft by September 2025. The draft law entered inter-ministerial consultation on 19th of September 2025 with the comment period ending 9 October 2025. The government's legislative plan aims for Cabinet approval by October 2025 and Parliamentary adoption well before the EU deadline. The law is slated to take effect on 1st of June 2026, which aligns with the Directive's transposition timeline.
Scope of Coverage: The draft law will apply to virtually all employers in Slovakia across private and public sectors, covering employees as well as job applicants, in line with the Directive's broad scope. Notably, certain equal-pay provisions already exist in Slovak legislation - for example, the Labor Code includes the principle of equal pay for equal work and prohibits pay discrimination on grounds of sex, and it even bans contractual pay secrecy clauses. The new law builds on this foundation by introducing the additional transparency measures required by the Directive. Enforcement will leverage existing institutions: oversight of the new duties will be carried out by the national labor inspectorates, under coordination of the Ministry of Labor.
Slovakia's draft legislation closely mirrors the Directive's core requirements, imposing several new obligations on employers aimed at increasing pay transparency and fairness.
Salary Disclosure in Job Posts: Employers will be required to disclose the initial wage or salary (or its range) for a position in job advertisements or before a job interview. The draft law further states that IF the range is included in the job ad, this obligation has been fulfilled. This pre-employment transparency rule enables informed and fair salary negotiations. In practice, HR departments must include a truthful pay range (based on objective criteria) in each job posting or offer communication. The draft law aligns with the EU directive's mandate that candidates have a right to know the pay level, and it explicitly forbids employers from asking candidates about their past remuneration during hiring. Recruitment processes and job descriptions must also be gender-neutral and non-discriminatory, so employers should review their job titles and hiring practices to eliminate biased language or criteria. These measures mean HR teams need to standardize how starting pay is determined (e.g. by experience or job grade) and ensure any staff involved in hiring are trained not to inquire about salary history, as such questions will be unlawful.
All employers must establish and maintain pay structures based on objective, gender-neutral job evaluation criteria. This requirement operationalizes the equal pay principle by attacking the root causes of pay gaps - e.g. undervaluation of work in female-dominated roles. In essence, companies need to define how jobs are valued using factors like skills, effort, responsibility, and working conditions (without referencing gender). The criteria used must additionally be agreed upon together with the worker representative, if any.
The draft law obliges employers to use such criteria consistently when setting pay and grading jobs. Practically, this might entail implementing formal job classification systems or reviewing existing pay schemes to ensure they don't inadvertently favor one gender. For HR and reward leaders, a key task is to audit current pay matrices and job descriptions - are pay differences between roles explainable by neutral factors? If not, adjustments will be needed to comply with the new standard of pay structure transparency.
Mirroring Article 7 of the EU Directive, the Slovak law will grant employees a right to request information about pay levels. Upon request, an employer must inform an employee of their own pay and the average pay for colleagues of the opposite sex in the same or a comparable job category. This enables employees to identify possible pay gaps.
Employers cannot retaliate against workers for asking, and importantly, pay secrecy can no longer be enforced - existing Slovak law already bans any clause that prevents staff from discussing or disclosing their wages, and the new act reinforces that workers "shall not be prevented from disclosing their pay" for purposes of equal pay claims.
Additionally, employers must annually remind employees of their right to request pay information, including instructions on how to request it. By increasing pay transparency internally, these measures may surface pay gaps that employers should be ready to explain or address.
The draft law introduces periodic pay gap reporting obligations for employers with more than 100 employees, in line with the EU Directive's thresholds. Affected employers will have to compile and submit data on gender pay gaps within their organization. The report must include the following metrics.
For employers with 100 - 249 employees, the reports must be submitted every three years, and employers with 250+ employees must submit it annually. These reports must be made public or at least shared with a designated state monitoring body so that workers, authorities, and the public can access the data. The deadline for submitting the reports will be 31st of March, and the reporting scope is the preceding year.
Practical implications: Employers crossing the 100-employee mark should prepare for significantly increased data analytics and disclosure duties. Before the law takes effect, such companies would be wise to perform trial calculations of their gender pay gap metrics. If gaps exist, you should document objective reasons for them or be ready to explain the differences. Remember that the law will also require management to attest to the accuracy of reported data, and workers' representatives will have the right to ask for clarifications on the reported figures. Ensuring data quality and understanding the story behind the numbers will be crucial to comply and to avoid reputational or legal risks.
A cornerstone of the Directive, which Slovakia is adopting, is a "stepwise corrective mechanism" for employers where the reported data reveals significant pay gaps. If an employer's pay reports show a gender pay gap exceeding 5% in any category of workers and the employer cannot justify this gap on the basis of objective, gender-neutral factors, and have not corrected the gaps within 6 months of reporting, the company will be required to conduct a joint pay assessment in cooperation with employee representatives. This must happen within two months of the aforementioned deadline. In other words, a 5%+ unexplained pay gap will trigger a structured review process.
During a joint assessment, the employer and worker representatives must analyze the pay structure, identify the causes of the gap, and develop an action plan to close unjustified differences. The draft law obliges employers in this situation to implement concrete corrective measures - for example, pay adjustments or other organizational changes - to resolve the identified disparities.
Proactively reviewing pay equity is strongly advised, so that any emerging gaps can be explained or addressed before they reach the threshold that mandates a formal joint assessment. (As my old teacher used to tell me, exams are fun for the well-prepared - so make sure you show up with your homework done).
If a joint assessment is required, be prepared to collaborate with trade unions or employee council representatives and potentially the labor inspectorate or equality body (since the authorities can be involved to ensure compliance). The outcome of a joint assessment - including findings and remedial steps - must be made available to the workforce and be submitted to the ministry of Labor.
A crucial point in the Slovak draft law is that the obligations apply universally - to all employers in both the private and public sectors. This means state institutions, municipalities, schools, hospitals, and other publicly funded or state-owned organizations will be subject to the same transparency and equal pay rules as private companies. Public employers will therefore need to introduce gender-neutral pay structures, disclose salary ranges in recruitment, respect the ban on pay history questions, and respond to employee pay information requests just like their private sector counterparts.
The only distinction the law makes is in relation to reporting frequency, which varies depending on headcount. All employers, regardless of size, are bound by the transparency obligations and employee rights, but pay gap reporting is mandatory only for organizations with 100 or more employees. Those with 250 or more will need to report annually, while those in the 100-249 bracket will report every three years. Employers under 100 staff are exempt from statistical reporting, but remain fully subject to all other duties under the act.
The Slovak legislation does include national clarifications to fit the Directive into the existing legal context. One example is enforcement: the draft assigns the role of monitoring compliance to Slovakia's labor inspectorates, with the Ministry of Labor coordinating - a practical implementation detail consistent with domestic labor oversight structures. Another point is the interplay with current anti-discrimination law: since Slovak law already prohibits gender-based pay discrimination and pay secrecy agreements, the new act reinforces these principles (e.g. confirming that any contractual gag orders about wages are null and void, as required by the Directive). The draft also underscores workers' right to appropriate compensation and shifts the burden of proof to the employer in cases of pay discrimination. While these concepts were largely present in EU law and transposed via the Anti-discrimination Act, the new law integrates them specifically for pay equity cases. For instance, it emphasizes that if an employer has not fulfilled the transparency obligations, they will bear the burden to prove that any pay gap is not discriminatory. This is not a deviation but rather a clarification aligning Slovak procedure with the Directive's Article 18.
Another minor clarification is that multiple Slovak laws will be amended in tandem (Labor Code, etc.) to support the new transparency regime. The Directive gave flexibility on how to implement its rules - Slovakia chose a combined approach of a standalone law plus ancillary amendments, which should ensure that concepts like "worker," "pay," "job category," and enforcement mechanisms are consistently defined across the legal system.
For HR and compliance leaders in Slovakia, the forthcoming law brings a new era of pay transparency and accountability. Even though the law's effective date (likely June 2026) is over half a year after adoption, organizations should start preparing now. Below are key steps and considerations:
In conclusion, Slovakia's draft pay transparency law represents a major shift toward openness in how workers are hired and paid. It aligns with EU-wide efforts to finally close the gender pay gap. Employers should view this not just as a compliance obligation but as an opportunity to improve their reward practices and employer brand. Those who move early to ensure fair and transparent pay will not only minimize legal risks - they are likely to gain a more motivated workforce and a reputation as equitable employers. The next months are a critical window to audit, plan, and educate. By the time the law takes effect in 2026, organizations that have done their homework will be well-placed to meet the requirements.
Sources: Official draft law materials (MPSVR SR); EU Directive 2023/970 (OJ L132, 17.5.2023); Press release and explanatory statements on Slovakia's transposition plan; Preliminary information PI/2025/120 by MPSVR SR; Smernica (EU) 2023/970 text.
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