Malta Pay Transparency Regulations 2025

Transparent and Predictable Working Conditions (Amendment) Regulations, 2025

Malta

RET-MT-NA-LN112OF-2025

Effective: August 27, 2025
In Force(In Force)
RegulationPay Transparency in HiringWage Discussion RightsEqual Pay Principles

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025 (LN 112 of 2025), published on June 27, 2025, and effective August 27, 2025, amends Malta's existing employment law to partially transpose the EU Pay Transparency Directive. This legislation introduces new pay transparency rights for both job applicants and existing employees, requiring employers to disclose initial pay or pay ranges for positions and allowing employees to request their individual pay levels and those of peers performing the same work. It marks a crucial step towards reducing the gender pay gap and fostering greater fairness in compensation practices across the Maltese labor market.

Overview

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, identified by Document ID RET-MT-NA-LN112OF-2025, represents a significant legislative update in Malta's employment law landscape. Published as Legal Notice 112 of 2025 on June 27, 2025, and entering into force on August 27, 2025, these Regulations amend the principal Transparent and Predictable Working Conditions Regulations (Subsidiary Legislation 452.126 of the Laws of Malta). The primary purpose of this amendment is to initiate Malta's transposition of the European Union's Pay Transparency Directive (Directive (EU) 2023/970), aiming to strengthen the principle of equal pay for equal work or work of equal value and to reduce the gender pay gap across the EU.

Historically, Malta has long upheld the principle of equal pay, enshrined in Article 27 of the Employment and Industrial Relations Act (Chapter 452 of the Laws of Malta), which mandates equal remuneration for work of equal value. The Equality for Men and Women Act (Chapter 456) and the Equal Treatment in Employment Regulations (Subsidiary Legislation 452.95) further reinforce these protections against discrimination in employment, including in matters of remuneration. The original Transparent and Predictable Working Conditions Regulations (S.L. 452.126), enacted in October 2022 via Legal Notice 267 of 2022, transposed EU Directive 2019/1152, focusing on providing workers with more comprehensive and timely information about their employment conditions and ensuring greater predictability in their work patterns.

The 2025 amendment introduces key innovations by granting specific pay transparency rights to both job applicants and existing employees. For the first time, prospective employees have the right to receive information about the initial pay or pay range for a position, along with any relevant collective agreement provisions, before commencing employment. Concurrently, current employees gain the right to request their individual pay level and the pay levels for categories of workers performing the same work, with employers obligated to respond within two months. These changes mark a crucial first step in Malta's journey towards full compliance with the EU Pay Transparency Directive, which has a transposition deadline of June 7, 2026, and signifies a broader cultural shift towards greater openness and fairness in compensation practices within the Maltese labor market.

Definitions

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, introduces and clarifies several key terms essential for understanding its scope and application. A pivotal new definition is that of an “applicant for employment,” which refers to any person actively seeking employment and who is currently being considered for engagement with a prospective employer. This definition is significant because it extends specific rights and entitlements related to pay transparency to individuals even before a formal employment contract is established, a novel concept within this particular area of Maltese legislation. Previously, many employment rights were primarily afforded to individuals already in an employment relationship, making this a forward-looking inclusion to prevent pay discrimination from the outset of the hiring process.

Another crucial term defined within the context of these Regulations is “pay level.” This is precisely defined as an employee's gross annual pay and the corresponding gross hourly pay. This dual definition ensures a standardized and comprehensive metric for evaluating remuneration, facilitating accurate comparisons and promoting transparency across different employment arrangements, including part-time and fixed-term work. The scope of “pay” itself is broad, encompassing not only the base salary but also various other components such as allowances, overtime payments, bonuses, commissions, holiday remuneration, and statutory bonuses and weekly allowances. This comprehensive understanding of 'pay' is vital for ensuring that all elements of compensation are considered when assessing pay equity and transparency, preventing employers from obscuring disparities through varied benefit structures.

While the Regulations introduce rights for employees to compare pay for those performing the “same work,” it is important to distinguish this from the broader concept of “work of equal value,” which is a central tenet of the overarching EU Pay Transparency Directive (Directive (EU) 2023/970). The principle of equal pay for work of equal value, already established in Malta through Article 27 of the Employment and Industrial Relations Act (Chapter 452), implies that jobs do not need to be identical to warrant equal remuneration, but rather should be assessed based on objective, gender-neutral criteria such as skills, effort, responsibility, and working conditions. The current amendment, LN 112 of 2025, represents a partial transposition, and future legislative actions are expected to expand the right to compare pay levels for work of equal value, aligning more fully with the EU Directive's comprehensive approach to combating gender pay gaps.

Covered Employers

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, applies broadly across the Maltese economy, encompassing every employer in Malta, irrespective of their size or the sector in which they operate. This universal applicability ensures that the new pay transparency obligations are not limited to large corporations but extend to small and medium-sized enterprises (SMEs) and across both the public and private sectors. The inclusive scope reflects the legislative intent to foster a culture of pay transparency and equity throughout the entire labor market, ensuring that all workers, regardless of where they are employed, benefit from these enhanced protections. This broad coverage is a direct consequence of Malta's commitment to transposing the EU Pay Transparency Directive, which itself has a wide application across Member States.

Furthermore, the Regulations extend its protections to all categories of workers. This includes not only full-time employees with indefinite contracts but also part-time workers, fixed-term employees, and, significantly, job applicants. The explicit inclusion of "applicants for employment" as a protected group marks a notable expansion of employment rights in Malta, ensuring that individuals seeking jobs are afforded transparency regarding initial pay or pay ranges before they even commence employment. This proactive approach aims to prevent pay discrimination from being embedded at the recruitment stage, promoting fairness in hiring practices across all employment types. The comprehensive nature of these Regulations underscores a commitment to equitable treatment for all individuals within the Maltese workforce.

While the current amendment (LN 112 of 2025) establishes foundational pay transparency measures, it is important to note that the full transposition of the EU Pay Transparency Directive (Directive (EU) 2023/970) by June 7, 2026, is expected to introduce further obligations, particularly concerning pay gap reporting. These future obligations are anticipated to include phased reporting requirements based on employer size, with larger companies (e.g., 250+ employees) likely facing annual reporting, and smaller companies (e.g., 100-249 employees) having triennial reporting duties. However, the current Regulations do not yet introduce these specific reporting thresholds or exemptions based on employer size for the immediate pay transparency requirements. All employers, regardless of headcount, are currently subject to the obligations regarding pay disclosure to applicants and the right of existing employees to request pay information. This iterative approach to transposition allows businesses to gradually adapt to the evolving regulatory landscape.

Employee Rights

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, significantly bolster employee rights by introducing new provisions aimed at enhancing pay transparency. A key right established for job applicants is the entitlement to receive information from a prospective employer regarding the initial pay or pay range for the position they are applying for. This information must be provided before the commencement of employment, ensuring that candidates can make informed decisions and are not disadvantaged by a lack of salary transparency. Additionally, where applicable, job applicants have the right to be informed of the relevant pay provisions stipulated in any collective agreement pertaining to the position. This proactive disclosure at the pre-employment stage is a crucial step towards curbing pay discrimination from the outset and promoting a more equitable hiring process.

For existing employees, the Regulations introduce a new and significant right: the ability to request, in writing, from their employer, at any time during their employment, their individual pay level. This empowers workers with direct access to their own compensation data. Furthermore, employees are also entitled to request information on the pay levels for categories of workers performing the same work as them. This right to compare pay with peers in similar roles is a powerful tool for identifying potential pay disparities and fostering accountability among employers. Upon receiving such a written request, the employer is legally obliged to provide the requested information within a reasonable period, which must not exceed two months from the date the request was made. This stipulated timeframe ensures that employees receive timely responses, enabling them to act on the information provided.

It is important to note the distinction in the current Maltese Regulations regarding comparative pay information. While the EU Pay Transparency Directive (Directive (EU) 2023/970) entitles employees to information on pay levels for categories of workers performing not only the 'same work' but also 'work of equal value,' Legal Notice 112 of 2025 currently limits this right to comparisons with those performing the 'same work.' This represents a partial transposition, and future legislative amendments are anticipated to broaden this right to include 'work of equal value' comparisons, aligning fully with the Directive's objectives. The overall aim of these new employee rights is to shift the balance towards greater openness and fairness in the workplace, providing workers with actionable information to address and challenge potential pay discrimination, thereby strengthening the enforcement of equal pay principles in Malta.

Pay Transparency Requirements

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, introduces specific and mandatory pay transparency requirements for employers in Malta, significantly impacting recruitment and ongoing employment practices. A primary requirement is the obligation for employers to provide job applicants with clear information regarding the initial pay or pay range for the position concerned. This disclosure must occur before the commencement of employment, ensuring that candidates are fully aware of the compensation structure prior to accepting an offer. This measure is designed to empower applicants, allowing them to make informed decisions and preventing situations where pay secrecy might perpetuate discriminatory practices or disadvantage certain groups of candidates. The information should be practical and easily accessible, fostering a more equitable and transparent hiring environment.

In addition to the initial pay or pay range, employers are also required to disclose, where applicable, the relevant pay provisions of any collective agreement that applies to the position being offered. This ensures that job applicants understand not only the individual salary but also any broader remuneration terms that might be governed by collective bargaining agreements. This requirement is particularly important in sectors where collective agreements play a significant role in determining wages and working conditions. While the EU Pay Transparency Directive (Directive (EU) 2023/970) suggests disclosure before the interview stage, Malta's current transposition allows for this information to be provided before the start of employment, offering employers some flexibility in their recruitment processes while still upholding the principle of pre-employment transparency.

For existing employees, the Regulations establish a right to request and receive information about their individual pay level, defined as gross annual and corresponding gross hourly pay. Furthermore, employees can request the pay levels for categories of workers performing the same work as them. Employers are mandated to provide this information in writing within a maximum period of two months from the date of the employee's written request. This obligation extends to all employers in Malta, regardless of their size or sector, and applies to all workers, including part-time and fixed-term employees. The Department for Industrial and Employment Relations (DIER) has also issued FAQs to provide further guidance, clarifying that 'pay level' refers to the salary band or range linked to the role, and that a written breakdown of the wage structure, including fixed and variable pay components, may be requested. These measures collectively aim to enhance internal pay transparency, enabling employees to identify and address potential pay discrepancies.

Reporting & Audit Obligations

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025 (LN 112 of 2025), as Malta's initial step in transposing the EU Pay Transparency Directive (Directive (EU) 2023/970), does not yet introduce comprehensive organizational-level gender pay gap reporting or mandatory pay audits. The current focus of these Regulations is primarily on individual pay transparency rights for job applicants and existing employees, rather than on collective reporting obligations for employers. This reflects an iterative approach to transposition, where foundational transparency measures are implemented first, with more extensive reporting and audit requirements anticipated in subsequent legislative phases.

However, the full implementation of the EU Pay Transparency Directive by June 7, 2026, will necessitate the introduction of phased reporting obligations for employers in Malta. Based on the Directive's requirements, companies with 250 or more employees are expected to face annual reporting obligations, likely beginning in 2027 for 2026 data. Employers with 150 to 249 employees are anticipated to report every three years starting in 2027, while those with 100 to 149 employees will likely have triennial reporting obligations beginning in 2031. Companies with fewer than 100 employees are not currently required to report under the Directive, unless Malta opts to lower this threshold in its national legislation. These future reporting requirements are expected to include detailed information such as mean and median gender pay gaps for total and variable pay, gender distribution across pay quartiles, and the proportion of employees receiving variable components by gender.

Furthermore, the EU Directive envisages mandatory Joint Pay Assessments when unjustified gender pay gaps of 5% or more are detected, requiring employers to collaborate with worker representatives to address these disparities. While LN 112 of 2025 does not yet specify the national authority or platform for submitting these future reports, it is expected that gender pay gap reports will need to be submitted to a designated national authority and made publicly accessible. Employers will also be required to certify the accuracy of their reports, consult with worker representatives, and share the findings with their employees. These forthcoming obligations will significantly increase the administrative burden and accountability for employers, necessitating robust data collection, analysis, and internal processes to ensure compliance with the evolving pay transparency framework.

Governance & Enforcement Bodies

The primary governmental body responsible for the governance and enforcement of employment law in Malta, including the Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, is the Department for Industrial and Employment Relations (DIER). The DIER operates under the Employment and Industrial Relations Act (Chapter 452 of the Laws of Malta) and is tasked with regulating employment contracts, ensuring that both employers and employees adhere to their respective rights and obligations. Its mission includes protecting workers' interests, promoting healthy industrial relations, and eliminating discriminatory practices within the workplace. The Department provides a range of services, including customer care, investigation of complaints, and mediation in trade disputes.

The DIER's Inspectorate Section plays a crucial role in monitoring and enforcing compliance with employment conditions. This section conducts inspections at workplaces to ensure that legal provisions, including those related to pay transparency, are observed. Employees or their representatives can lodge complaints with the DIER if they believe their rights under the Regulations have been infringed. The Department is equipped to investigate these complaints, mediate between parties, and, where necessary, refer cases to the Industrial Tribunal or the Law Courts for adjudication. The 2025 amendments to the Employment and Industrial Relations Act (Act XIV of 2025) have further strengthened the DIER's enforcement capabilities by increasing fines for breaches of employment law and extending the prescriptive period for initiating proceedings, thereby providing the Department with more time and stronger deterrents to ensure compliance.

Beyond the DIER, the Industrial Tribunal serves as an independent adjudicatory body for employment-related disputes, including those concerning discriminatory treatment and breaches of employment conditions. Employees who feel their rights under the Transparent and Predictable Working Conditions Regulations have been violated can refer the matter to the Industrial Tribunal for redress. The National Commission for the Promotion of Equality (NCPE), established under the Equality for Men and Women Act (Chapter 456), also plays a vital role in promoting gender equality and combating discrimination, including in the realm of pay. The NCPE conducts investigations, provides support to victims of discrimination, and issues recommendations on equality-related matters, complementing the DIER's enforcement efforts by focusing on broader equality principles and systemic issues.

Monitoring & Evaluation

The monitoring and evaluation of compliance with the Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, primarily falls under the purview of the Department for Industrial and Employment Relations (DIER). The DIER employs an Inspectorate Section specifically tasked with carrying out inspections at workplaces across Malta. These inspections are conducted to ensure that employers are adhering to all prescribed conditions of employment, which now explicitly include the new pay transparency obligations. The monitoring process is both proactive, involving ongoing programs targeting specific sectors, and reactive, triggered by specific complaints lodged by employees or their representatives. This dual approach allows the DIER to maintain a general oversight of the labor market while also addressing individual instances of non-compliance effectively.

When a complaint is lodged, the DIER initiates an investigation to ascertain whether a breach of the Regulations has occurred. The Department's officials are responsible for gathering evidence, interviewing relevant parties, and assessing the employer's adherence to the pay transparency requirements, such as providing salary information to job applicants or responding to employee requests for pay data within the stipulated two-month period. The DIER also engages in mediation and conciliation efforts to resolve disputes amicably, aiming to recover any unpaid wages or benefits due to employees. In cases where amicable resolution is not possible or where serious breaches are identified, the DIER has the authority to institute criminal proceedings against employers, leveraging the strengthened penalty regime introduced by Act XIV of 2025.

While the current Regulations (LN 112 of 2025) do not yet mandate specific audit frequencies or detailed evaluation criteria for organizational-level pay transparency, the full transposition of the EU Pay Transparency Directive (Directive (EU) 2023/970) by June 2026 is expected to introduce such mechanisms. Future legislative developments are anticipated to include requirements for gender pay gap reporting, which will involve employers collecting and submitting data on various pay components and gender distribution across pay quartiles. These reports will likely be subject to certification for accuracy and consultation with worker representatives, providing a more structured framework for monitoring and evaluating pay equity at an organizational level. The DIER, in its role as the national authority, will likely be responsible for overseeing these future reporting and audit obligations, ensuring that employers not only comply with individual transparency rights but also address systemic pay disparities through regular self-assessment and public disclosure.

Enforcement & Penalties

Enforcement of the Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, and other employment laws in Malta is primarily carried out by the Department for Industrial and Employment Relations (DIER). The DIER is empowered to investigate complaints, conduct workplace inspections, and initiate legal proceedings against non-compliant employers. A significant development in strengthening enforcement mechanisms came with the enactment of Act XIV of 2025, published on June 6, 2025, and entering into force on August 6, 2025. This Act substantially amended the Employment and Industrial Relations Act (Chapter 452), specifically Article 45, by introducing significantly harsher penalties for breaches of employment law, including those related to the Transparent and Predictable Working Conditions Regulations.

Under the revised penalty structure, an employer found guilty of a first offense for contravening or failing to comply with any recognized condition of employment, or any provision of the EIRA or regulations made thereunder, faces a fine ranging from €2,000 to €5,000. This represents a substantial increase from the previous fine range of €232.94 to €2,329.37. For repeat offenders, the penalties are even more stringent, with fines escalating to a minimum of €5,000 and potentially reaching up to €7,000. These increased fines are intended to serve as a strong deterrent against non-compliance and underscore the Maltese legislator's commitment to treating employment law breaches as serious offenses. Furthermore, Act XIV of 2025 also extended the prescriptive period for initiating criminal proceedings for such offenses from one year to two years, providing the DIER with a longer timeframe to investigate and prosecute breaches effectively.

In addition to monetary fines, the courts, at the request of the prosecution and upon proof of the amount owed, may order employers to refund or pay any sums due to affected employees, such as unpaid wages or benefits. In cases where statutory holidays with pay were not granted, the employer may be ordered to pay an amount equivalent to the wages for such holidays. Employees who believe their rights have been violated also have the right to refer the matter to the Industrial Tribunal for redress, which can order reasonable monetary compensation to the aggrieved party. The appeals process for decisions made by the Industrial Tribunal typically follows the procedures outlined in the Employment and Industrial Relations Act. While the Transparent and Predictable Working Conditions Regulations (S.L. 452.126) originally specified a fine of not less than €450 for non-compliance, the newer, higher penalties introduced by Act XIV of 2025 now apply to breaches of these Regulations, reflecting a strengthened enforcement regime across all employment conditions.

Relationship to Other Laws

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, operates within a well-established legal framework in Malta, interacting closely with several other key pieces of employment and equality legislation. Foremost among these is the Employment and Industrial Relations Act (Chapter 452 of the Laws of Malta, or EIRA), which provides the overarching legal structure for employment relationships in Malta. The Regulations are subsidiary legislation promulgated under the EIRA, meaning they derive their authority from and must be consistent with the principal Act. The EIRA defines fundamental employment conditions, outlines the powers of the Department for Industrial and Employment Relations (DIER), and establishes the Industrial Tribunal for dispute resolution. The recent Act XIV of 2025, which amended the EIRA, significantly increased penalties for breaches of employment law, thereby strengthening the enforcement mechanisms for the Transparent and Predictable Working Conditions Regulations as well.

The Regulations also build upon and complement Malta's existing anti-discrimination and equal pay legislation. The principle of equal pay for equal work or work of equal value is explicitly mandated by Articles 26 and 27 of the Employment and Industrial Relations Act. Further reinforcement comes from the Equal Treatment in Employment Regulations (Subsidiary Legislation 452.95), which gives effect to various EU Directives on equal treatment and prohibits discriminatory practices in employment, including remuneration, on grounds such as sex, religion, disability, and age. The Equality for Men and Women Act (Chapter 456) also plays a crucial role, promoting equality for men and women and establishing the National Commission for the Promotion of Equality (NCPE) to combat discrimination. These laws collectively form a robust legal foundation that the new pay transparency measures are designed to enhance, providing additional tools for identifying and addressing pay disparities that might stem from discriminatory practices.

While the Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, represents Malta's initial step in transposing the EU Pay Transparency Directive (Directive (EU) 2023/970), it is important to note that it is a partial transposition. This means that further legislative amendments are expected by the Directive's full transposition deadline of June 7, 2026. These future amendments are anticipated to introduce additional obligations, such as a ban on asking about candidates' salary history, the right for employees to compare pay for work of equal value (beyond just the 'same work'), gender pay gap reporting for larger companies, and the prohibition of pay secrecy clauses. Therefore, the current Regulations should be viewed as an evolving component of Malta's legal framework, with subsequent legislation expected to further align national law with the comprehensive requirements of the EU Directive, potentially introducing new interactions and precedence considerations with existing laws.

International Context

The Transparent and Predictable Working Conditions (Amendment) Regulations, 2025, is deeply rooted in Malta's obligations as a member state of the European Union, specifically serving as a partial transposition of the EU Pay Transparency Directive (Directive (EU) 2023/970). This Directive, adopted on May 10, 2023, aims to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women across the EU. Its provisions include measures for pay transparency before employment, the right to information on pay levels, gender pay gap reporting, and mechanisms for enforcement and redress. Malta's initial transposition through LN 112 of 2025 addresses key aspects of Articles 5 and 7 of the EU Directive, focusing on pre-employment pay disclosure and employees' right to request pay information. The full transposition of the Directive is required by June 7, 2026, indicating that further legislative developments are anticipated in Malta to fully align with all its requirements, including the broader concept of 'work of equal value' and mandatory pay gap reporting.

Beyond the European Union framework, Malta's commitment to pay equity and non-discrimination is also shaped by its adherence to international labor standards, particularly those established by the International Labour Organization (ILO). Malta has been a member of the ILO since January 4, 1965, and has ratified numerous ILO Conventions, including the fundamental ones. Relevant to pay equity are the ILO Equal Remuneration Convention, 1951 (No. 100), which Malta ratified on June 9, 1988, and the ILO Discrimination (Employment and Occupation) Convention, 1958 (No. 111), ratified by Malta on July 1, 1968. Convention No. 100 calls for equal remuneration for men and women for work of equal value, while Convention No. 111 aims to promote equality of opportunity and treatment in employment and occupation, with a view to eliminating any discrimination. These international conventions provide a global normative framework that underpins both EU law and national legislation in Malta, reinforcing the long-standing principle of non-discrimination and equal pay as fundamental human and labor rights. The current Regulations, by enhancing pay transparency, contribute to Malta's ongoing efforts to give practical effect to these international commitments and to address persistent gender pay gaps in line with global trends towards greater workplace equity.

Implementation Timeline

DateMilestoneStatus
2022-10-21Publication of Transparent and Predictable Working Conditions Regulations (S.L. 452.126) via Legal Notice 267 of 2022, transposing EU Directive 2019/1152.In Force
2022-08-01Effective date for rights and obligations under S.L. 452.126 for all employment relationships.In Force
2025-06-06Publication of Employment and Industrial Relations (Amendment) Act (Act XIV of 2025), increasing penalties for employment law breaches.In Force
2025-06-27Publication of Transparent and Predictable Working Conditions (Amendment) Regulations, 2025 (Legal Notice 112 of 2025).In Force
2025-08-06Entry into force of Employment and Industrial Relations (Amendment) Act (Act XIV of 2025).In Force
2025-08-27Entry into force of Transparent and Predictable Working Conditions (Amendment) Regulations, 2025 (Legal Notice 112 of 2025).In Force
2026-06-07Deadline for full transposition of EU Pay Transparency Directive (Directive (EU) 2023/970) by all EU Member States.Awaiting Further Transposition
2027 (expected)Annual gender pay gap reporting for employers with 250+ employees (for 2026 data), as per EU Directive.Proposed
2027 (expected)Triennial gender pay gap reporting for employers with 150-249 employees, as per EU Directive.Proposed
2031 (expected)Triennial gender pay gap reporting for employers with 100-149 employees, as per EU Directive.Proposed

Compliance Checklist

RequirementAction RequiredDeadline
Pre-employment pay disclosure to applicantsProvide initial pay or pay range for the position to all job applicants.Before commencement of employment
Collective agreement pay provisions disclosureInform job applicants of relevant pay provisions from collective agreements (if applicable).Before commencement of employment
Respond to employee pay information requestsProvide individual pay level and pay levels for categories of workers performing the same work upon written request.Within two months of written request
Maintain accurate pay recordsEnsure comprehensive and accurate records of all pay components (salary, allowances, bonuses, overtime, etc.) for all employees.Ongoing
Review recruitment processesIntegrate pay transparency requirements into job advertisement, interview, and offer letter stages.Ongoing
Train HR and managementEducate staff on new pay transparency obligations, employee rights, and proper response procedures.Ongoing
Assess current pay structuresProactively review existing pay scales and remuneration policies for potential disparities.Ongoing
Prepare for future reporting obligationsBegin collecting and analyzing data for potential gender pay gap reporting (mean/median pay gaps, pay quartiles, variable pay components) in anticipation of full EU Directive transposition.Ongoing (leading up to 2026-06-07)
Consult with worker representativesEngage with employee representatives on pay transparency measures and future reporting/audits (as per EU Directive).Ongoing (as applicable)
Ensure non-retaliation policiesImplement and communicate policies protecting employees who exercise their pay transparency rights from adverse treatment.Ongoing

Sources and References

SourceType
Transparent and Predictable Working Conditions Regulations (S.L. 452.126)official
Equal Treatment in Employment Regulations (S.L. 452.95)official
Equality for Men and Women Act (Chapter 456)official
Department for Industrial and Employment Relations (DIER)government
ILO Equal Remuneration Convention, 1951 (No. 100)official
ILO Discrimination (Employment and Occupation) Convention, 1958 (No. 111)official
Role of the Department of Industrial and Employment Relations - Public Servicegovernment

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