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How long will the interim period for pay transparency rules last?

The interim period does not run the same for every country: it ends at the latest on the EU transposition date, but often earlier, and does not mean that nothing applies until then.

The interim period is the time between now and the moment when your country has transposed the EU directive on pay transparency into national legislation. The directive itself sets a deadline for this: Member States must complete the transposition by 7 June 2026 at the latest. How long the interim period still lasts for you personally therefore depends on the legislative pace in the country where your business is established — and that pace varies.

It is important to be clear about this right away: interim does not mean that nothing applies until that date. In many Member States, national legislation on equal pay between men and women already exists, with its own obligations and its own deadlines. The interim period is the period during which the European rules have not yet been fully incorporated into your national law, not a period without any obligation. What exactly already applies to your situation, what still needs to be transposed, and what will only become relevant for reporting, you can find out for your own situation in a few questions.

What the interim period actually means

Unlike a regulation, an EU directive does not have direct effect. It obliges Member States to create their own legislation within a specified period that achieves the same result. Until that national law exists or comes into force, formally the old national framework still applies — supplemented by what already existed specifically on equal pay in that country. The interim period is therefore not a legal vacuum, but a transition from one framework to another, with a hard deadline set by the directive itself.

Why the duration differs by country

Transposition is national implementation. One parliament handles a bill faster than another, and some countries choose to bring in certain parts earlier than legally required, for example because they fit with an existing national initiative on equal pay. This means that two businesses of the same size, in two different Member States, can face the same obligation at two different times. For an employer with establishments in several EU countries, the interim period therefore does not run the same everywhere, and that is precisely where planning often goes wrong.

Where businesses stumble in practice

The most common miscalculation is that businesses treat the final EU date as the date when everything changes for them, when their own country has already adopted legislation earlier or maintains existing national obligations. A second problem is that the interim period is confused with a trial period: people think that implementation is still optional, when in fact documentation, job classification and workflows can best be built during this phase, so that they are ready as soon as the national law comes into force. A third problem lies in the assumption that all components — from the pay range in a job advertisement to the reporting obligation — come into force at the same time. In practice, the directive has a phased approach: some obligations apply without any threshold, others only with a certain number of employees, and reporting comes up again later.

Semi-public employers and the interim period

For semi-public employers — think of organisations with a public task but a private legal form — there is often an additional layer: they may already fall under existing national equal treatment rules that are stricter than what applies to private employers. The interim period changes little here; it runs in parallel, but does not replace existing obligations until national transposition explicitly provides for it. If you are unsure whether an existing obligation will remain or be replaced, it is advisable to check this with the competent supervisory authority or a lawyer, as this varies by sector and by country.

What you can do now

Regardless of how long the interim period in your country lasts, the core is the same: the direction of the rules is set, only the exact entry date is not. Job vacancy texts, the request for current salary, and the classification of positions are components you can prepare during the interim period already without having to wait for a legislative change. In the knowledge base, sorted by topic, each obligation is indicated whether it is already relevant now, what is still pending transposition, and what only applies at reporting. You can read which source is behind it, and how we keep it traceable, on the page on how the information is created.

Are you uncertain whether the interim period for your country and your sector has already ended, or is still ongoing? Do the free quick-scan or check the frequently asked questions about the interim period — both can be consulted without an account and provide initial guidance, without making a judgment about your specific situation.

This article is general information and not legal advice.