The Pay Transparency Directive in Hungary is becoming an increasingly hot topic, ever since the EU Pay Transparency Directive (Directive (EU) 2023/970) introduced one of the most comprehensive regulatory frameworks in Europe aimed at reducing the gender pay gap and strengthening equal pay for equal work. While the Directive has already set clear obligations for employers across the EU, each Member State must transpose the rules into national law by June 2026.

Hungary has not yet published the final transposition law, but the expected regulatory direction is already apparent. Employers will face new obligations related to salary disclosure, pay reporting, job architecture and internal data gathering – making early preparation essential.

This article summarises how the Directive is expected to be implemented in Hungary, what changes employers should anticipate, and how organisations can prepare.

Overview of the EU Pay Transparency Directive

The Directive aims to eliminate unjustified gender-based pay differences by increasing transparency throughout the entire employment lifecycle. The key elements include:

Key obligations under the Directive

• Disclosure of the starting salary or its range in a way that ensures transparent negotiations (e.g., in the job posting or before the interview). 
• Ban on asking candidates about previous salary history.
• Right to information: employees may request information on their individual pay level and on the average pay levels of colleagues performing the same or equal-value work, broken down by gender.
• Gender pay gap reporting: companies must report pay-gap data on average and median pay, including bonus entitlements.
• Reporting deadlines depending on company size (for example: 250 + employees: first report by 7 June 2027; 150–249 employees: first report by 7 June 2027 and every three years; 100–149 employees: by 7 June 2031 and every three years). 

The Hungarian regulatory context

Current Hungarian rules

Hungary’s Labour Code already contains the principle of equal pay for equal work, but the legislation does not currently require:

• structured gender pay reporting,
• disclosure of salary ranges in job advertisements,
• job-evaluation frameworks,
• or detailed pay transparency rights for employees.

This means that the Directive will introduce significant new obligations for employers once implemented.

Status of transposition

Hungary has not yet adopted the national implementing legislation, but:

• preliminary professional consultations are ongoing,
• employers expect substantial amendments to the Labour Code,
• new reporting and disclosure obligations will need to be aligned with Hungarian GDPR and data-protection rules.

Given the scope of the Directive, most experts anticipate that Hungarian employers will need to overhaul their internal pay-structure documentation by 2026.

Why the Directive matters for Hungary

According to Eurostat (2023), Hungary’s gender pay gap stands at approximately 17.8%, which is significantly higher than the EU average of around 12%, highlighting the growing need for systematic transparency tools. For many organizations, compliance will not only be a legal obligation but also a key employer-branding and retention factor.

Expected obligations for employers in Hungary

Although the exact text of the Hungarian implementation law is pending, the Directive gives a clear indication of upcoming requirements.

Salary transparency in recruitment

Employers will need to:

• include salary ranges in job advertisements, or
• provide the salary range before the first interview,
• refrain from collecting salary-history information from applicants.

This will likely require changes to job posting templates, recruitment policies and HR communication practices.

Employee “right to information”

Hungarian employees will gain the right to request:

• their individual pay level,
• the average pay level of employees performing the same or equal-value work,
• data broken down by gender,
• Furthermore, employees will have the right to share their own pay information, and employers will no longer be allowed to prohibit this.

Employers must provide this information in writing, within a reasonable deadline, and without retaliation.

Mandatory gender pay-gap reporting

Some companies will need to submit structured reports including:

• average and median pay gaps,
• bonus and benefit differences,
• category-based segmentation of employees,
• explanations of gender-neutral job-evaluation criteria.

These reports may be published or submitted to authorities, depending on the final Hungarian transposition.

Joint pay assessment

If a company identifies a 5%+ unexplained pay gap, and cannot justify it with objective, gender-neutral reasons, the employer must:

• conduct a joint assessment with employee representatives,
• analyse root causes,
• adopt corrective action plans.

Compensation and legal remedies

Compensation and legal remedies

The Directive requires:

• more robust sanctions,
• shifting of the burden of proof to the employer,
• and full back-pay compensation for victims of discrimination.

These mechanisms will need to be codified in Hungarian labour legislation.

Implementation Timeline in Hungary

2026: Transposition deadline

Hungary must implement the Directive into national law by 7 June 2026.

2027–2028: First reporting deadlines

Similar to other Member States, Hungary will likely apply a phased reporting schedule:

• 2027: First reports for employers with 250+ employees
• 2030: First reports for employers with 150–249 employees
• 2031+: Employers with 100–149 employees join the reporting obligation

(Exact dates will depend on the Hungarian implementing law.)

What employers should prepare now

Despite the missing national legislation, organisations can and should start preparing:

Internal preparations

• Review and formalise job descriptions and job-architecture systems
• Define transparent, gender-neutral pay-evaluation criteria
• Introduce clear salary-band structures
• Conduct internal pay audits and identify potential risk areas

Data & reporting preparations

• Establish reliable HR and payroll data sources
• Ensure GDPR-compliant data handling
• Prepare draft reporting frameworks and dashboards

Organisational readiness

• Train HR, recruitment and management teams
• Update recruitment policies and templates
• Establish communication guidelines for employees and candidates

Benefits and Risks for Employers

Benefits

• Stronger employer branding and trust
• Improved retention and engagement
• Reduced risk of discrimination claims
• Transparent and more efficient pay-management structures

Risks of non-compliance

• Administrative fines
• Legal actions and compensation claims
• Reputational damage
• Potential disadvantages in public procurement processes

Being proactive can significantly mitigate risks and position companies as attractive employers in a competitive labour market.

Conclusion

The EU Pay Transparency Directive will bring substantial changes to the Hungarian labour market. While the final national legislation is still in progress, employers should not wait until the last minute. Transparent pay structures, proper job evaluation, reliable data collection and clear communication practices will become essential elements of compliance.

Early preparation not only ensures readiness once the Hungarian transposition is published, but also strengthens trust, fairness and long-term workforce stability.

If your organisation needs support in assessing its current pay structure, preparing for the Directive or implementing compliant HR processes, our experts are ready to assist.

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