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Pay Transparency in Portugal: 2026 Employer Guide

Legal information last reviewed 17/08/2026

EU Pay Transparency Directive Status Portugal: Draft Published: Consultation to 25 Aug 2026

Portugal has not enacted transposing legislation for the Directive. A first draft amending the Labour Code and Law 60/2018 had already gone to public consultation in April 2026, led by the Commission for Equality in Labour and Employment alongside the Ministry of Labour, Solidarity and Social Security, but that draft was not finalized by the 7 June 2026 EU-wide deadline. On 5 August 2026 the government published a fuller draft bill for public consultation, open for comment until 25 August 2026. The critical feature of Portugal's model is who does the calculating: rather than an employer self-reporting regime, the draft has the Ministry of Labour calculate the gender pay gap indicators, mean gap, median gap and the same for supplementary or variable pay, directly from data employers already submit in the Relatorio Unico (Single Report), with the labour inspectorate (ACT) expected to act proactively on the results rather than only respond to complaints. The draft confirms the Directive's tiered reporting bands on top of the existing 50-plus threshold used for Law 60/2018 reporting, and fixes the first reporting deadline for employers with 150 to 249 employees at 7 June 2027, covering the 2026 reference year. For Portuguese employers in that band, 2026 is therefore already the first reporting reference year, not a year to wait and see. Because the bill has not been finalized or passed by the Assembly of the Republic, exact figures such as fine amounts remain provisional and could still change before enactment.

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.

Portugal already regulates gender pay equity through Law 60/2018, in force since February 2019, which requires companies with 50 or more employees to submit annual pay data to the Ministry of Labour and to correct unjustified gender pay gaps identified by the authorities. Portugal missed the 7 June 2026 EU-wide transposition deadline for the Pay Transparency Directive (2023/970), but on 5 August 2026 the government published a full draft bill for public consultation, open until 25 August 2026. The model is authority-led: public bodies combine employer data already filed in the Relatorio Unico with administrative data to calculate the pay gap indicators, rather than requiring employers to self-report a separate figure. The draft confirms that employers with 150 or more workers must submit their first report by 7 June 2027, covering the 2026 reference year, so 2026 is already the first reporting year for those employers even though the transposition law is not yet enacted.

Under current law, only Portuguese employers with 50 or more employees must file annual pay reports via the Relatorio Unico. The August 2026 draft bill confirms EU Directive reporting bands at 100 to 149, 150 to 249 and 250-plus employees, with the Ministry of Labour calculating the pay gap indicators from data already on file rather than employers self-reporting; duties like the salary history ban and pay range disclosure are expected to apply to employers of any size.

What employers must do in Portugal

All employers, regardless of size

  • Comply with the general equal pay for equal work principle set out in the Labour Code
  • Prepare for an expected ban on asking candidates about salary history once the transposition law passes
  • Prepare for expected gender-neutral job title and job advertisement requirements

Employers with 50 or more employees (existing Law 60/2018 regime)

  • Submit annual pay data broken down by gender, sector, profession and qualification to the Ministry of Labour
  • Share the annual pay report with employee representatives
  • Prepare an evaluation plan within 120 days if the Ministry flags an unjustified pay gap, and correct it within 180 days

Employers with 100 to 249 employees (confirmed under the August 2026 draft bill)

  • Have the Ministry of Labour calculate mean and median gender pay gap figures, including variable pay, directly from the employer's existing Relatorio Unico filing on a triennial cycle, rather than compiling and self-reporting a separate figure
  • Disclose salary ranges to candidates in job postings or before interview
  • Conduct a Joint Pay Assessment with worker representatives if an unjustified pay gap of 5% or more persists for six months
  • For employers with 150 to 249 employees specifically: submit the first report by 7 June 2027, covering the 2026 reference year

Employers with 250 or more employees (expected under the EU Directive transposition)

  • Report gender pay gap data annually rather than every three years once transposition is complete
  • Report pay quartile distribution data by gender
  • Respond to individual employee requests for average pay information by gender within two months

Key deadlines

21 Feb 2019 Law 60/2018 entered into force, creating Portugal's existing pay reporting and evaluation plan regime
Apr 2026 First draft transposition bill for the EU Pay Transparency Directive opened for public consultation
7 Jun 2026 EU-wide transposition deadline. Portugal did not meet it; the bill remained in consultation and drafting
5 Aug 2026 Government publishes a fuller draft bill, confirming the authority-led model and the 150-employee reporting deadline, for public consultation
25 Aug 2026 Public consultation on the August 2026 draft bill closes
7 Jun 2027 First gender pay gap report due for employers with 150 to 249 employees, covering the 2026 reference year
2031 (expected) First reporting deadline contemplated for employers with 100 to 149 employees, once Portuguese law is finalized

Penalties for non-compliance in Portugal

Under the existing Law 60/2018 regime, administrative fines for pay reporting or pay discrimination violations reportedly range from around 2,040 to 61,200 euros depending on severity, alongside possible exclusion from public procurement. The penalty regime for the new Directive-based obligations has not yet been fixed because the transposition law is still in draft.

The Authority for Working Conditions (ACT) enforces reporting and evaluation plan duties, while the Commission for Equality in Labour and Employment (CITE) investigates individual pay discrimination complaints.

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
portugal
Lisbon
Portugal
32500 EUR
Above market
Unbalanced
Jane Smith
Project Manager
Senior
portugal
Lisbon
Portugal
45000 EUR
Above market
In Market
Michael Brown
Data Analyst
Mid
portugal
Porto
Portugal
39000 EUR
Above market
In Market
Emily Johnson
QA Engineer
Mid
portugal
Porto
Portugal
36000 EUR
Above market
In Market
Robert Wilson
HR Manager
Senior
portugal
Braga
Portugal
50000 EUR
Above market
Above Market
Sarah Davis
Marketing Specialist
Junior
portugal
Braga
Portugal
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

Mean Male Pay N/A
Mean Female Pay N/A

Pay gap insights

Missing data

Add employee data to see pay gap insights

Tenure distribution

Pay gap per level (quartiles)

-

Male
Female

Frequently asked questions about pay transparency in Portugal

No. Portugal missed the 7 June 2026 EU transposition deadline. A fuller draft bill amending the Labour Code and Law 60/2018 was published for public consultation on 5 August 2026, open until 25 August 2026, but it has not been passed by the Assembly of the Republic, so Portuguese employers are still operating under the pre-existing Law 60/2018 regime while the new draft is finalized.