Wage transparency in Portugal: what does your company need to do now?
1 de June, 2026
On June 7, 2026, “salary secrecy” will cease to exist in Portugal. The European Pay Transparency Directive (EU 2023/970 ) comes into force on that date and brings with it one of the biggest changes in employment law in recent decades.
More than imposing transparency rules, it will force companies to (re)evaluate the value of their work.
Only a few days to go. The question is: is your company ready?
Why this Wage Transparency Directive?
The aim of the Directive is to ensure that men and women receive the same pay for the same work, closing the gender pay gap that persists in the European Union, where women earn on average around 12% less than men – a gap that in Portugal stands at 8.6%.
These figures are nothing new. What has changed with the directive is the obligation to act and demonstrate this in a transparent way, with concrete data and well-defined processes.
What changes from June?
Recruitment
The new legislation establishes transparency rules from the very first stages of a recruitment process and in the interaction with candidates:
- Companies need to define salary ranges in advance before opening any vacancies;
- All job advertisements must indicate the salary or salary range for the position;
- It is now forbidden to ask candidates about their previous salary.
In practice, this means that HR teams have to review and formalize remuneration policies before posting any job offers.
Employee relations
As of June 7, any employee can apply:
- Information on the objective criteria that determine your salary and career progression;
- Your individual salary and the average salary of colleagues in the same or similar positions, broken down by gender.
The Pay Transparency Directive states that the company is obliged to respond to all requests for information from employees. If there are salary differences, they must be justified on the basis of criteria such as performance, seniority or clearly defined progression rules.
In the mandatory reports
Depending on the size of the company, there are new obligations to disclose data on gender pay gaps:
| Company size | Reporting obligation | First report |
|---|---|---|
| 250 or more employees | Annual report | 2027 |
| 150 to 249 employees | Triennial report | 2028 |
| 100 to 149 employees | Triennial report | 2031 |
| Less than 100 employees | Exempt from formal reporting | – |
Even companies with fewer than 100 employees, which are exempt from submitting formal reports, are subject to all the other rules: transparency in job offers and the right to information on workers’ salaries.
Please note: if a gender pay gap of more than 5% is not objectively justified within 6 months, the company will have to carry out a joint audit with employee representatives and apply mandatory corrective measures.
What should the HR department do this month?
With the date of entry into force so close, the time to act is now. Where to start?
- Map functions and salaries;
- Implement an objective job evaluation;
- Review remuneration and progression policies;
- Adapting advertisements and recruitment processes;
- Prepare systems for collecting and analyzing salary data;
- Train HR and leadership on salary transparency.
We will soon be publishing a complete checklist to help your company go through each of these steps.
To conclude…
Companies that proactively adopt pay transparency are in a better position to attract and retain talent in a labor market that is increasingly demanding in terms of fairness and transparency.
And this change starts long before reports and audits – it starts with the way organizations value, support and care for their people on a daily basis.
FAQs (Frequently Asked Questions)
- Does the directive apply to all Portuguese companies?
Yes. All companies are subject to the rules on transparency in recruitment and workers’ right to salary information. Reporting obligations vary according to the size of the company. - What happens if the company doesn’t comply?
Non-compliance can result in administrative sanctions, legal action by employees and reputational damage. In the event of a dispute, the burden of proof lies with the company. - Has the Portuguese transposition law been published?
Portugal has not yet published the transposition law. However, the obligations of the European directive apply from June 7, 2026. - What are the consequences of non-compliance?
Failure to comply can result in fines, legal action and reputational damage. In the event of a dispute, it is the company that has to prove that it did not discriminate (and not the employee who has to prove that they were discriminated against). - Where should the company start?
The starting point is an internal analysis of pay by function and gender. Identify existing differences, document salary criteria and review recruitment processes. If necessary, consult experts. - What happens if the gender pay gap is more than 5%?S can it help in other areas of the company?
If a gap of more than 5% is not objectively justified within 6 months, the company is obliged to carry out a joint audit with employee representatives and implement corrective measures.