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How can we, as lawyers, help you meet the requirements of the new remuneration law?

9 June 2026

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New equal pay legislation, which will come into effect on 7 June 2026, represents a fundamental shift for employers from passive compliance with anti-discrimination rules to an active obligation to demonstrate pay justice. As current legislation did not provide employees with sufficient tools to check their rights, the state is introducing a comprehensive transparency system that requires precise internal process settings, categorisation of jobs according to their value, and regular reporting. For companies, this means the necessity of reviewing not only payroll records but also overall personnel documentation and recruitment procedures, in order to avoid the risk of high penalties and the shifted burden of proof.

  1. Legal audit of remuneration: Identification of risky 5 % discrepancies and the establishment of objective justifications for them.
  2. Documentation Review: Amendment of employment contracts, internal wage regulations and GDPR records.
  3. Methodology and reporting: Assistance with categorising positions by job value and preparing reports for the ministry.
  4. Representation in disputes: Employer defence during labour inspection audits or claims for damages. .

The most important dates introduced by the new remuneration law for employers

  • 31 July 2026: Obligation to have transparent salary structures in place.
  • 7 June 2027: First report for companies with 150 or more employees.
  • 7 June 2031: First report for companies with 100–149 employees.

Practical advice on a key change in remuneration – it's not salary but reward that counts

Finally, another important piece of information that may be key for many. This time, the legislator has left nothing to chance and the difference in remuneration will not be derived from wages but from reward. Reward includes the basic component of wages, minimum wage, but also additional components that the employer provides at their discretion. This will prevent pretending that employees of the same category have the same gross wage and camouflaging differences through additional components. Penalties are high, which is precisely why a well-structured remuneration system is necessary. Do not forget that the system is uncompromising: reversed burden of proof, retrospective payment of the difference in remuneration, and penalties.

Checklist

Work CategorisationYou have employees divided into categories according to job value and not just by job title
Wage structureAre your salary criteria (complexity, responsibility, etc.) documented and gender-neutral?
 Recruitment auditDo your advertisements include a starting salary and are they gender-neutral?
 HR Preparation:Are HR staff trained not to ask about previous salary?
Contract reviewHave you removed invalid wage secrecy clauses from employment contracts?
TransparencyDo you have an internal process in place to respond to written employee requests for payroll data within 2 months?
 ReportingDo you know when exactly you submit your first report to the ministry based on your number of employees?