EU Pay Transparency Directive Status Belgium: Deadline Missed, Extension Sought
Belgium published a draft transposition bill on 15 March 2025 that folds Directive 2023/970 into the existing 2012 Gender Pay Gap Law, and the file has since been under review in parliament's Committee on Social Affairs, Employment and Pensions. Rather than let the transposition lapse quietly, Belgium formally requested a six month postponement from the European Commission in the days before the 7 June 2026 deadline; the Commission has indicated it does not intend to offer a general delay or suspension mechanism to member states, so it is not yet clear whether Belgium's specific request will be granted. Progress has also been uneven across Belgium's regions and language communities: the French Community partially transposed the Directive's right to information provisions for its own public sector employees from January 2025, and the Flemish Region approved a decree transposing the Directive for its public sector on 13 March 2026, but full federal transposition covering private sector employers is still pending. The draft reportedly goes further than the EU minimum in places, for example proposing to lower the pay gap threshold that triggers a mandatory joint pay assessment from the Directive's standard 5% to 3%, though this and other details remain proposals until the federal bill is actually enacted.
What is Pay Transparency, and who does it apply to?
The EU Pay Transparency Directive (Directive (EU) 2023/970) is a binding EU law requiring pay equity for equal work between women and men. It introduces mandatory rules around salary disclosure, pay gap reporting, and worker rights.
Belgium's existing pay equity framework rests on the 2012 Law to Combat the Gender Pay Gap, which already requires private employers with 50 or more employees to produce a biennial gender disaggregated remuneration report. Belgium also had to transpose the EU Pay Transparency Directive by 7 June 2026, a deadline it missed, formally asking Brussels for extra time just before the cutoff.
Under current Belgian law, employers with 50 to 99 employees file a simplified report and those with 100 or more file a full gender pay breakdown; the pending EU transposition is expected to layer additional obligations, such as salary range disclosure and individual pay information rights, onto all Belgian employers regardless of size, though the federal bill was not yet law as of mid-2026.
What employers must do in Belgium
Employers with 50 to 99 employees (current law)
- File a simplified biennial remuneration report covering direct pay, benefits and bonuses on a full-time equivalent basis
Employers with 100+ employees (current law)
- File a full biennial remuneration report broken down by worker category, seniority, function and qualifications, disaggregated by gender
- Draw up an action plan if a significant pay gap is detected
Proposed under the draft federal transposition, not yet in force
- A lower 3% (instead of the EU standard 5%) unjustified pay gap threshold that would trigger a mandatory joint pay assessment with worker representatives
- Salary range disclosure to candidates before or during recruitment
- A ban on asking candidates about their salary history
- An individual employee right to request pay information for comparable roles
Key deadlines
Penalties for non-compliance in Belgium
Under Belgium's current 2012 law, non-compliance can bring criminal fines of 400 to 4,000 euro or administrative fines of 200 to 2,000 euro, alongside separate civil sanctions under collective bargaining rules. The pending draft transposition would need to add effective, proportionate and dissuasive penalties as required by the EU Directive, with some commentary pointing to fines up to roughly 3,900 euro per year, though exact figures are not final until the federal bill passes.
The Federal Public Service for Employment, Labour and Social Dialogue reviews remuneration reports, working with the Institute for the Equality of Women and Men, which sets the gender neutral evaluation criteria and can support victims in pay discrimination cases.
How TalentUp can help you with Pay Transparency Compliance
Below you can see a preview of our platform, where we help you stay compliant with Pay Transparency by spotting pay inconsistencies and structural risks in your compensation strategy, analysing data from your company.
Book a demo| Name | Level | Location | Salary | Labels | Actions |
|---|---|---|---|---|---|
|
John Doe
Software Developer
|
Mid
|
Brussels
Belgium
|
32500 EUR
Above market
|
Unbalanced
|
|
|
Jane Smith
Project Manager
|
Senior
|
Brussels
Belgium
|
45000 EUR
Above market
|
In Market
|
|
|
Michael Brown
Data Analyst
|
Mid
|
Antwerp
Belgium
|
39000 EUR
Above market
|
In Market
|
|
|
Emily Johnson
QA Engineer
|
Mid
|
Antwerp
Belgium
|
36000 EUR
Above market
|
In Market
|
|
|
Robert Wilson
HR Manager
|
Senior
|
Ghent
Belgium
|
50000 EUR
Above market
|
Above Market
|
|
|
Sarah Davis
Marketing Specialist
|
Junior
|
Ghent
Belgium
|
34000 EUR
In market
|
In Market
|
MEAN PAY
39.4K EUR
MEDIAN PAY
37.5K EUR
MEAN FEMALE PAY
38.3K EUR
MEDIAN FEMALE PAY
36K EUR
MEAN MALE PAY
40.5K EUR
MEDIAN MALE PAY
39K EUR
Gender gap
Variable pay by gender
General gender pay gap
Pay gap insights
Add employee data to see pay gap insights
Tenure distribution
Pay gap per level (quartiles)
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Frequently asked questions about pay transparency in Belgium
No. Belgium missed the 7 June 2026 transposition deadline for its federal private sector rules and formally asked the European Commission for a six month extension just before the cutoff.