Legal Alerts/10 Jul 2026
Finland Moves to Implement the EU Pay Transparency Directive
Finland is implementing the EU Pay Transparency Directive through a package of legislative amendments in line with the minimum requirements of the Directive. The amendments suggested in the recent government proposal are scheduled to enter into force on 1 January 2027.
New obligations for employers
The baseline of the government proposal is that there must be no pay differences between employees performing the same or equivalent work, unless such differences can be justified by objective and gender-neutral criteria.
The concept of "same or equivalent work" is central to the proposed legislative changes, forming the basis of pay reporting, pay assessments and employees' right to information. Pay comparisons must be based on relevant, objective and gender-neutral criteria (including skills, workload, responsibility and working conditions) and “soft skills” must not be undervalued. For these assessments, comparisons may extend to employees who worked for the employer at a different point in time, not only those employed concurrently.
The government proposal introduces a range of new obligations for employers, such as:
- Employers with 100 or more employees must report gender pay gap data by employee group. Where an unjustified gap of 5% or more is found, the employer must in some cases conduct a pay assessment together with its employee representatives.
- At the recruitment stage, employers must disclose the relevant role’s pay or a pay range to candidates. Furthermore, employers are prohibited from enquiring about the candidates’ pay history.
- On request, the employer must provide the employee with information regarding their individual pay level and the average pay levels of the group of employees performing the same or equivalent work. Pay confidentiality clauses are prohibited.
- Employers must communicate the criteria used to determine the employees’ pay. Employers with 50 or more employees must also communicate the criteria they use to determine the employees’ pay development.
- A three-year limitation period for compensation claims in pay discrimination cases is introduced.
- Where an employer has failed to meet any pay transparency obligation, the burden of proof shifts automatically to the employer.
Steps employers should take before the legislative changes enter into force
Employers should:
- audit their pay structures to identify and remedy unjustified gender pay gaps,
- ensure that pay criteria are clearly defined and communicated,
- ensure that recruitment practices follow the new disclosure and transparency obligations, and
- engage employee representatives in the process.
If you have any questions concerning the implementation of the EU Pay Transparency Directive or its implications for your organisation, please contact us or other members of our Employment team.
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