In brief

Just days before the 7 June 2026 transposition deadline, Belgium has formally requested a six-month extension from the European Commission to implement the EU Pay Transparency Directive (2023/970). It remains to be seen whether the Commission will agree to this request, particularly as it reiterated only last week that it does not intend to introduce any delay or suspension mechanism.

Belgium is not alone. Many Member States are facing delays, reflecting the significant legal and operational complexity of the new rules.

However, one key message stands out: an extension—if granted—does not change what employers need to do.

The direction is clear and irreversible: greater transparency, increased scrutiny, and enforceable equal pay obligations.

Key takeaways

Whether the deadline is June or later in 2026, organisations will need to ensure:

  • Robust and defensible job classification frameworks
  • Transparent and consistent pay structures
  • Preparedness for mandatory reporting and disclosure obligations
  • Readiness to engage in informed social dialogue

These are not measures that can be implemented in a matter of weeks. They require time, data, and careful alignment across HR, legal and leadership teams. Companies that start early will be in a significantly stronger position—both from a compliance and risk management perspective, and in terms of employee trust and employer branding. Early preparation will also prove valuable in the event of litigation, enabling employers to substantiate and defend their pay decisions.

We are actively supporting clients across industries at every stage of their pay transparency journey, and would be pleased to further assist you.

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