Estonia: EU Pay Transparency Directive legislation at a glance

While many EU member states transposed the EU Directive as a single regulatory package, Estonia is implementing a unique split strategy. Certain pay transparency provisions took effect on July 13th, 2026, based on amendments to the nation’s Employment Contracts Act (Töölepingu seadus - TLS, or 837 SE). Separate legislation is expected to complete the EUPTD transposition.

The currently effective legislation addresses key aspects of the EUPTD with regard to transparency and recruitment, staying close to the baseline of the Directive’s requirements and to most other member states.

As mentioned above, employers must provide salary or salary range information, as well as information about applicable collective agreements, to prospective employees prior to the first formal interview. 

• Pay history ban: Employers cannot ask prospective employees about their current or past compensation.
• Pay secrecy ban: Employers cannot prohibit employees from discussing or disclosing pay. This legislation voids any historical or template pay secrecy clauses in employees’ contracts.
• The legislation establishes the requirement for equal pay for equal work or work of equal value; any differences must be justified by objective, gender-neutral criteria.

Under Estonia’s split strategy, we expect the remaining legislation to track the EUPTD baseline requirements. This includes:

• Pay structure requirements in line with the above.
• Right to information legislation, likely specifying that employees must be annually informed of their rights and that employers must respond to information requests in 2 months or less.
• Reporting requirements are expected to begin in 2028 for employers with 150+ employees.
• Unjustified pay gaps of 5% or more will likely have a six-month window for remediation before triggering a Joint Pay Assessment.

Since Estonia has been developing its infrastructure and systems for pay data reporting, it has made some key tools available now for voluntary use. These include:

• Palgapeegel (“Pay Mirror”), an online tool for checking an organization’s gender pay gap. This uses data that has already been reported to the state. It can be used by any organization with at least three male and three female staff.
• The PALK Project, which offers job-evaluation methodologies and training. This may be useful in preparing compensation structures to align with future requirements. The project will be open through December 31st, 2026.