Remuneration has long since ceased to be merely a matter for the payroll department. It is linked to the design of HR processes, equal pay for women and men, job evaluation and the building of trust between employers and employees. The EU Pay Transparency Directive introduces rules on recruitment, employees’ access to pay information, and the assessment and reporting of the gender pay gap. Companies must therefore review not only their existing procedures but also their overall approach to people management.

Although the directive establishes a common legislative framework, individual countries differ in how they implement it and in the preparedness of employers. How are the new rules being put into practice in Hungary, Slovakia, Croatia and Slovenia? We have looked at current developments, companies’ experiences and the challenges they face during implementation.

Hungary: Preparations are underway, but progress varies

Based on the experience of Grant Thornton Hungary’s Human Capital team, Hungarian companies are paying increasing attention to pay transparency, although their progress in preparing for the new requirements varies considerably. Some organisations have already launched comprehensive programmes to review their remuneration systems and job structures, while others are still assessing their current practices or waiting for further details of the Hungarian legislation. The level of preparedness does not necessarily depend on company size. Leadership commitment, the maturity of existing HR systems and the extent to which an organisation considers pay transparency a strategic priority are equally important factors.

In our experience, many companies believe that their existing HR and payroll data provide a solid foundation for meeting the new requirements. However, the picture is more mixed when it comes to job structures and evaluation systems. While some organisations already have documented job evaluation frameworks based on objective criteria, others are still developing them. Establishing which roles involve the same work or work of equal value is essential for conducting reliable pay gap analyses. Approaches to assessing gender pay gaps also differ: some companies carry out regular analyses, while others address the issue only occasionally or have yet to establish an appropriate methodology.

One of the biggest challenges in preparing for pay transparency is ensuring that jobs can be compared objectively and identifying pay differences that cannot be justified. This can be particularly complex for companies where job classifications have evolved over time using different criteria. Expectations regarding potential pay adjustments also vary. Some organisations anticipate significant additional costs, while others expect changes to be necessary only for certain roles. There are also companies that do not foresee any substantial adjustments. Employers are also concerned about the potential for internal tensions and employee dissatisfaction as pay differences become more visible.

According to our Hungarian experts, management preparation is another area that has yet to receive sufficient attention in many companies. While organisations are primarily focusing on analysing pay data, reviewing job classifications and ensuring regulatory compliance, managers often lack the information and guidance they need to respond effectively to employees’ questions about remuneration. Companies also have different expectations about the impact of the changes. Some see opportunities to promote fairer pay practices and strengthen employee trust, while others are more concerned about growing internal tensions. This makes it particularly important to plan internal communication and prepare managers well before the new requirements take effect.

Our experience in Hungary suggests that companies are most likely to seek external expert support for tasks requiring specialised methodologies and close cooperation across different business functions. These include job evaluation and the development of job architecture, the design of pay structures and salary bands, and gender pay gap analysis. Organisations also seek professional guidance on legal compliance, management training and internal communication.

The experiences of Hungarian companies are similar in several respects to the practical challenges faced by organisations in Slovakia. In both countries, key priorities include establishing objective job evaluation systems, ensuring reliable pay data, and developing transparent remuneration policies. Although Hungarian companies are at different stages of preparation, many of the necessary technical and organisational steps can already be taken. Starting early can make future regulatory compliance easier while also helping organisations build more consistent pay practices and strengthen employee trust.

Slovakia: initial practical experience

In Slovakia, the rules came into force on 7 June 2026, making it one of the first countries in the region where their practical implications can be observed. Initially, companies viewed pay transparency primarily as a new legislative and administrative obligation. Gradually, however, they are realising that the preparation process also raises broader questions concerning remuneration systems, career progression, job evaluation and communication with employees.

Larger companies and international groups are showing the greatest interest in preparing for this, as they analyse their pay structures and prepare for future reporting obligations. In smaller firms, on the other hand, we often encounter the view that the issue does not concern them, as they will not be subject to mandatory reporting. There is also a widespread misconception that, if employees do not complain about their pay, pay disparities are not a concern for the company. However, transparency also applies to recruitment, informing job applicants and establishing objective pay rules, in every organisation regardless of size.

The challenge often lies not in the pay analysis itself, but in identifying comparable job roles and assessing whether they involve the same work or work of equal value. The job evaluation methodology published by the Ministry of Labour, Social Affairs and Family of the Slovak Republic can serve as a useful guide. At the same time, companies need high-quality data, correctly set pay bands and cooperation between HR, payroll teams, legal departments, finance and management.

Croatia: preparation is more important than waiting for the law

The deadline for transposing the directive expired on 7 June 2026, but as of October 2026, Croatia had not yet completed the transposition. The existing legal framework already recognises the principle of equal pay and prohibits discrimination. However, the directive is expected to bring more structured processes and clearer information for both employers and employees. Until the rules are adopted, companies should distinguish between obligations that already apply and new requirements. International groups can draw on global remuneration frameworks, job grading systems and reporting processes.

However, pay data alone does not indicate readiness; this also depends on the maturity of HR processes, data quality and management buy-in. The most challenging task will be to identify roles that constitute work of equal value. It is not enough to compare job titles; skills, effort, responsibility and working conditions must also be taken into account. A pay gap does not automatically imply discrimination. However, unexplained differences must be thoroughly investigated, and conclusions should not be based solely on aggregate figures.

Communication is equally important. Even a technically sound analysis can cause confusion if managers are unable to explain how starting salaries are determined, what factors influence pay rises, and why colleagues’ pay varies. Transparency does not mean that everyone has the same salary, but that differences are based on clear, objective and non-discriminatory criteria. Companies can already review the quality of their HR and payroll data, update job descriptions, document the criteria for starting salaries, pay rises and variable remuneration, allocate responsibilities amongst HR, payroll, legal, finance and management, and draw up a communication plan. Getting started early allows time to identify any issues and make any necessary adjustments.

Slovenia: averages do not tell the whole story

Slovenia has missed the deadline for transposition. The draft bill was submitted to the Economic and Social Council in February 2026 and entered preliminary inter-ministerial consultation in May, but has not yet been published. The aim is to adopt the law by March 2027, though this is a planned, not a confirmed, deadline. The principle of equal pay is already guaranteed by Article 133 of the Employment Relationships Act (ZDR-1). The proposed legislation is intended to introduce more specific requirements regarding transparency and reporting on the gender pay gap.

According to Eurostat, the unadjusted gender pay gap in Slovenia stood at 8.0% in 2024, which was below the EU average of 11.1%. More recent data from the Slovenian Statistical Office (SURS) show that in October 2025 it stood at 3.3%, whilst in October 2024 it was 5.0%. However, the national average does not capture all the differences. In financial and insurance activities, the gap reached 22.2% in October 2025, and in health and social care 17.2%. Eurostat and SURS data relate to different periods and statistical coverage, so they cannot be directly compared.

A distinctive feature of the Slovenian labour market is the use of collective agreements and job classifications based on education, which, however, do not always correspond to the actual requirements of individual roles. Smaller employers, in turn, often have less formalised remuneration rules. In both cases, it is important to evaluate job roles according to objective, gender-neutral criteria. Practical support in this area is offered by the PAY DAY project, which provides advice and training and is developing a free online tool for evaluating and grouping roles of equal value.

Key takeaways

Experience from four countries shows that legislative readiness and employers’ actual readiness are not the same thing. Regardless of the current status of transposition, companies should focus on four areas:

• Data and criteria: ensure high-quality HR and payroll data and document the rules for starting salaries, pay rises and variable remuneration.
• Job evaluation: identify comparable roles based on objective and gender-neutral criteria.
• Remuneration analysis: examine pay gaps and assess whether they are explained by objective factors, rather than relying solely on overall figures.
• Communication: prepare managers to explain remuneration rules and answer employees’ questions.

This issue is not limited to large companies, as every employer deals with recruitment, informing job applicants and establishing objective remuneration rules. Early preparation can make it easier for companies to comply with legislation in the future, whilst also helping to build more consistent and credible remuneration systems.