Pay transparency 2027: what the new law means in workplaces

Directive and the Finnish proposal

Directive (EU) 2023/970 of the European Parliament and of the Council strengthens the principle of equal pay through pay transparency and enforcement measures. Member States were required to transpose it into national law by 7.6.2026. In Finland the deadline was not met.

In summer 2026 the government submitted to Parliament proposal HE 129/2026 vp, which would amend the Act on Equality between Women and Men and related laws. The laws are intended to enter into force on 1.1.2027. Parliament's Employment and Equality Committee prepared its report on 22.10.2026 and supported approval of the proposal. Two dissenting opinions were attached to the report.

At the end of October 2026 the law had not yet been confirmed. The matters described below are based on the proposal and the directive, and details may change in parliamentary proceedings. Check the final content on Finlex once the law has been published.

Recruitment: salary must be disclosed in advance

Under the proposal, the employer would have to tell the job applicant the starting salary or its range, and the pay terms of the collective agreement applied to the job. The information would not have to be in the job advertisement, but it would have to be given at the latest before the job interview.

In addition, the employer should not ask the applicant about pay in current or previous employment relationships. The directive directly prohibits enquiring about pay history. For a job seeker this means that the salary negotiation starts from the information given by the employer, not from one's own previous pay.

Employee's right to pay information

An employee could request in writing information on their own pay level and on the average pay levels, broken down by gender, of groups of employees doing the same or equal-value work. According to the directive, the information must be provided within a reasonable time and at the latest within two months of the request.

The right does not apply to an individual colleague's pay. According to the proposal, the request could also be made through a staff representative. If the information would reveal the pay of an identifiable person, group-level information would be given to the staff representative or the Equality Ombudsman. According to the directive, an employee also cannot be prevented from disclosing their own pay in order to enforce equal pay.

Employer's new obligations

According to the proposal, all employers would have to tell employees the criteria on which pay and pay levels are determined. Employers with at least 50 employees would also have to tell them the criteria for pay progression. The criteria must be objective and gender-neutral.

In addition, every employer should have a method for grouping jobs by their demands, for example according to skills, workload, responsibility and working conditions. The method may be based on a collective agreement, a commercial system or the employer's own model.

Tell the applicant the starting salary or salary range before the interview
Remove questions about pay history from recruitment forms
Record the pay criteria in an understandable form
Group the tasks for assessing equal value
Prepare a response template for pay information requests

Reporting by size class

According to the proposal, the reporting obligation would apply to employers with at least 100 employees on a regular basis. The information would be reported to the incomes register, and Statistics Finland would pass it on to the Equality Ombudsman. The directive phases the timetable by employer size:

At least 250 employees: first report by 7.6.2027 at the latest, then annually
150–249 employees: first report by 7.6.2027 at the latest, then every three years
100–149 employees: first report by 7.6.2031 at the latest, then every three years
Fewer than 100 employees: no reporting obligation

Joint pay assessment and legal protection

If reporting shows that the average pay of women and men differs by at least five per cent in some group of employees, and the difference is not objectively justified or corrected within six months, the employer must, under the directive, carry out a joint pay assessment with employee representatives. According to the proposal, failure to comply with the obligation would result in a penalty payment.

According to the proposal, the limitation period for a claim for compensation for pay discrimination would be extended to three years. The Ombudsman for Equality gives advice in suspected cases of pay discrimination, and in Salary Radar you can compare pay in your occupation with the statistics.

Employees should already now find out what their own pay is based on and which collective agreement applies to the job. Once the law is in force, it is worth making a pay information request in writing and keeping the reply. Employers should go through their pay structure before the first reporting so that any unjustified differences can be corrected in time.

Frequently asked questions

When does the Pay Transparency Act enter into force?

Under the proposal, 1.1.2027. At the end of October 2026 the proposal was being considered by Parliament and the law had not been confirmed.

Can I find out my colleague's salary?

No. Under the proposal you could request your own pay level and the average pay of the group doing the same or equivalent work, by gender, but not an individual person's pay.

Does the reporting apply to a small company?

No. Reporting would apply to employers with at least 100 employees. However, providing pay information to applicants and the employee's right to information would apply to all employers.

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Sources

The article is general information and does not replace the guidance of an authority, a lawyer or an adviser. Check up-to-date information from the sources.