From June – more transparency in salaries: what’s important to know

The Ministry of Social Security and Labour (SADM) presents a brief memo on guarantees.

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Guarantees currently provided in the Labour Code:

• the obligation to pay the same remuneration for the same or equivalent work;
• a transparent and non-discriminatory recruitment process: gender-neutral job advertisements, the obligation to state the proposed basic salary or its range in the job advertisement;
• gender-neutral and objective remuneration systems are mandatory for employers employing 20 or more employees;
• employers, upon request by employee representatives, must provide information on average remuneration by gender and job group;
• administrative liability may be applied to the employer for violations of remuneration calculation and determination.

Guarantees entering into force from 7 June 2026:

Pre-contractual relations:

• it is prohibited to ask a candidate about their current remuneration;
• before the job interview, the candidate must be informed about the provisions of the collective agreement applicable to that position.

Confidential information:

• an employee’s remuneration is not confidential information if they seek to exercise their right to fair remuneration.

Compensation for damages:

• all pecuniary (money + in-kind) and non-pecuniary damage is compensated, lost opportunities for 3 years are compensated if the employee’s right to fair remuneration has been violated;
• the 6-year limitation on penalties is abolished.

Requirements for remuneration systems:

• although the requirements enter into force on June 7, remuneration systems must be reviewed and prepared by December 31;
• remuneration systems are mandatory for all employers, regardless of their size;
• positions must be grouped into groups of equal value according to the following criteria: skills, effort, responsibility, working conditions, qualifications;
• objective criteria and procedures for determining remuneration and additional remuneration must be established;
• procedures for remuneration indexation and increase (for 50 or more employees) must be established.

Guarantees entering into force from 1 January 2027:

Updated and prepared remuneration systems:

• methodological assistance published by the State Labour Inspectorate () and publicly available training (Facebook) can help review and prepare remuneration systems;
• a tool developed by the European Institute for Gender Equality can help evaluate, compare, and group positions. You can find the tool here: EU-wide guidelines on gender-neutral job evaluation and classification: Step-by-step toolkit | European Institute for Gender Equality.

Data provision to “Sodra”:

• all employers will have to provide “Sodra” with monthly information about each employee;
• information is provided once and updated when changes occur: working time norm and regime, job group number specified in the remuneration system;
• monthly data provided: total accrued remuneration, additional remuneration, paid working time;
• Information for January is provided in February, etc.

“Sodra” provides calculated data to employers:

• monthly average employee remuneration by job groups and annual average from 2028;
• will provide the average employee remuneration for the first time in March for January;
• will provide employers with detailed annual remuneration gap reports showing detailed indicators of remuneration differences;
• the first annual gap reports from 2028 for 2027 – for employers with 150 or more employees, and from 2031 for 2030 – for 100 to 149 employees.

Provision of information to employees, employee representatives, the State Labour Inspectorate, the Office of the Equal Opportunities Ombudsperson:

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• employees will have the right at any time to request the employer to provide data on their monthly hourly remuneration and the average monthly hourly remuneration of employees in the same category by gender, and from 2028 – also the average annual hourly remuneration from 2028. The employee will be able to request and receive this data also through employee representatives, the State Labour Inspectorate, or the Office of the Equal Opportunities Ombudsperson.
• Employers will be obliged to provide employees with access to the remuneration transparency reports received from “Sodra”.

Remuneration difference:

• Employees performing the same or equivalent work must be paid the same remuneration, but it is noted that remuneration may differ due to objective reasons, such as employee performance, qualifications, experience, etc.

Joint remuneration assessment:

• If, after receiving the remuneration gap report from “Sodra”, the employer does not correct an unjustified remuneration gap within 6 months, a joint remuneration assessment must be initiated, involving employee representatives. The purpose of this assessment is to correct the remuneration gap;
• such assessments may be carried out from 2028.

Sanctions:

• if employers fail to provide the requested data to employees, employee representatives, or institutions, administrative liability and corresponding fines may be applied to them.