Although it misses the 7 June 2026 transposition deadline, its significance lies in the fact that it redefines compliance from disclosure of pay to regulation of internal pay structures themselves.

Most new obligations will not take effect until 1 January 2028, meaning Czechia will miss the 7 June 2026 transposition deadline by approximately 18 months, with pay gap reporting for employers with 100 or more employees delayed further to 1 January 2031.

While the draft may be refined before finalisation, it already signals a broader regulatory shift: Czechia is not merely implementing the Pay Transparency Directive but reinterpreting it as a framework for organisational pay governance, rather than a reporting regime. Employers operating in Czechia will need to prepare for a number of requirements that are more onerous than the Pay Transparency Directive baseline, including a universal mandatory remuneration system, a separate documented benefits system and an expanded enforcement role for the Ombudsman.

Key takeaways for employers

Czechia has published its draft legislation to transpose the EU Pay Transparency Directive (Directive (EU) 2023/970). Here is what employers operating in Czechia need to know:

• Most provisions will not take effect until 1 January 2028, meaning Czechia will miss the 7 June 2026 transposition deadline by approximately 18 months. Reporting for employers in the lower threshold (100-149 employees) begins from 1 January 2031.
• All employers must create a formal remuneration system, which goes beyond the Pay Transparency Directive’s requirements and presents a significant additional compliance burden, especially for SMEs.
• Employers providing non-pay monetary benefits must create a separate documented system with objective, non-discriminatory criteria - an entirely new obligation not found in the Pay Transparency Directive.
• Pre-employment pay disclosure is narrower than the Pay Transparency Directive requires: employers need only disclose the "minimum" wage or salary, not the full initial pay level or range.
• The Ombudsman (Public Defender of Rights) will have an expanded enforcement role, including the power to represent employees in court proceedings.
• Joint pay assessments (“remuneration assessments”) involve a complex new process including a 30-day waiting period for workers to organise representation if none exists.
• Fines for major breaches are capped at CZK 1,000,000 (approximately £35,000)

What does the Czechia draft law include?

Transposition timeline: a late but phased approach

Czechia will miss the 7 June 2026 deadline. The draft provides for a phased implementation, with the bulk of new provisions effective from 1 January 2028, and some measures applying from 1 January 2027. The lower pay gap reporting threshold (capturing employers with 100 or more employees) will not come into force until 1 January 2031, in line with the Pay Transparency Directive's own timetable.

This late transposition follows a pattern seen in several other EU Member States, such as France, Ireland and the Netherlands. Employers should use this additional lead time wisely: Divergent timelines and approaches across the EU only increase complexity and administrative burden.

Pre employment obligations: a narrower approach to pay disclosure?

The Pay Transparency Directive requires employers to inform job applicants of the “initial pay level or its range,” determined using objective, gender neutral criteria. The Czech draft adopts a narrower formulation, obliging employers to disclose only the minimum wage or salary - falling short of the initial pay level or pay range envisaged by the Directive. At the same time, it goes further than the Pay Transparency Directive by also requiring employers to provide information about other monetary benefits before employment contract negotiations begin.

This approach may amount to under-implementation. By requiring disclosure only of a floor figure rather than a range, the draft gives employers greater flexibility but introduces infringement risk if the European Commission considers the measure insufficient to meet the Pay Transparency Directive’s transparency obligations.

The draft also transposes the Pay Transparency Directive’s salary history ban, prohibiting employers from relying on an applicant’s current or previous remuneration.

Mandatory remuneration systems: a major new compliance requirement

One of the most significant aspects of the Czech draft is the requirement for all employers to establish a formal, documented remuneration system, set out in an internal regulation or collective agreement. This system must include a classification of roles into groups based on the value of work, assessed by reference to complexity, responsibility and strenuousness.

This goes well beyond the Pay Transparency Directive, which requires pay criteria to be accessible but does not mandate a formal documented system for every employer.

The Czech job evaluation criteria also differ from the Pay Transparency Directive. The Directive specifies skills, effort, responsibility and working conditions, whereas the Czech draft uses complexity, responsibility and strenuousness - reflecting existing Czech labour law tradition but potentially creating alignment issues.

In addition, employers who provide non-pay monetary benefits must create a separate documented system for those benefits, with objective and non-discriminatory criteria. This has no equivalent in the Pay Transparency Directive and creates an additional compliance layer.

Individual pay information rights: some Czech additions

Workers may request information on their own pay and the average pay in their work group, broken down by gender. The Czech draft adds procedural detail that goes beyond the PTD: requests must be made in writing.

The employer may restrict the use of this information to equal pay purposes, but only if it makes a written determination to that effect - a procedural requirement not found in the Pay Transparency Directive.

Where disclosure would reveal an individual employee's pay, the Czech draft channels the request through the Ombudsman rather than through workers' representatives or the labour inspectorate.

Joint pay assessments: a more elaborate process

Where a pay gap of 5% or more is identified and cannot be justified by objective, gender-neutral criteria, employers must carry out a "remuneration assessment". The Czech draft imposes a more elaborate process than the Pay Transparency Directive envisages.

The assessment must be discussed with trade unions and works councils. If no employee representatives exist, the employer must publish the information in a manner customary and accessible to all employees, and allow a 30-day period for workers to organise. Only if no trade union or works council is formed after this waiting period may the employer proceed unilaterally.

The assessment itself must be comprehensive, covering the proportion of men and women in each work group, average pay levels, identified disparities and their causes, the proportion of parents who experience an increase in renumeration after maternity/paternity/parental leave, proposed remedial measures with timescales, and an evaluation of any previous measures. The completed assessment must be published in a manner accessible to all employees and provided to trade unions, the works council, the Ministry, and (on request) the labour inspectorate and the Ombudsman.

The Pay Transparency Directive itself imposes no deadline for completing the assessment; the Czech draft requires completion within two months of the expiry of the six-month remedial period.

Enforcement: an empowered Ombudsman and modest penalties

The Czech draft assigns a significantly expanded role to the Ombudsman (Public Defender of Rights). Beyond collecting data and publishing reports, the Ombudsman will evaluate pay information, advise employees, issue opinions on employer remedial measures, and - most notably - represent employees in court proceedings. This means that employers may face a more active and potentially adversarial equality body.

The draft expands the reversed burden of proof: where an employer breaches its transparency obligations, it must prove that it has not violated the principle of equal treatment, unless it can show the breach was "manifestly unintentional or minor", rather than the Pay Transparency Directive’s exemption for breaches which are “manifestly unintentional and minor”.

On the sanctions side, fines are capped at CZK 1,000,000 (approximately GBP 35,000) for major breaches such as failure to create a remuneration system or violations of the joint assessment process, and up to CZK 400,000 (approximately GBP 14,000) for lesser breaches such as restricting pay information. Whether these penalty levels are "effective, proportionate and dissuasive" - as the Pay Transparency Directive requires - is open to question, particularly for larger employers.

The Czech draft also provides for financial compensation for non-pecuniary damage arising from pay discrimination.

Pay secrecy ban and other provisions

The draft includes a broad prohibition on employers restricting employees from sharing information about their pay, salary or other monetary benefits - a faithful transposition of Article 7(5) of the PTD.

One notable gap in the published draft is public procurement compliance: the Pay Transparency Directive requires Member States to ensure that economic operators in public contracts comply with equal pay obligations and allows exclusion of operators with an unjustified 5% or greater pay gap. This does not appear to be addressed in the current draft text.

What should employers do now?

Even though the main provisions will not apply until 1 January 2028, the breadth and depth of the Czech draft means that preparation should begin now. The mandatory remuneration system and benefits system requirements, in particular, will require significant groundwork for employers that do not already have formal pay structures in place. Employers should also begin to consider how they will collect, structure and report the data needed for the new pay gap reporting obligations, and should review their recruitment processes to ensure compliance with the pre-employment disclosure and salary history ban provisions. Employers should monitor updates, as the Ministry will determine by decree the content of the report on the pay gap and the method of calculating the gender pay gap.

Multinational employers should assess the Czech draft alongside their broader EU Pay Transparency Directive compliance strategies, noting the areas where the Czech approach is more onerous than the Pay Transparency Directive baseline - particularly the universal remuneration system requirement, the benefits system obligation, and the expanded Ombudsman role - as well as the areas where it is potentially more favourable, such as the centralised pay gap reporting model and the narrower pre-employment pay disclosure requirement.

We will continue to monitor developments in the transposition of the Pay Transparency Directive across all Member States and provide updates as the Czech legislative process progresses.

In the meantime, please contact our PTD team for advice on Pay Transparency Directive compliance.