The purpose of the new rules is not to ensure that everyone receives the same pay, but that differences in remuneration for the same work or work of equal value can be justified by objective, gender-neutral criteria. Employers should therefore review how pay is determined, whether job descriptions are structured, and whether the necessary data is available to identify pay gaps later. Monitoring domestic implementation, reviewing recruitment processes, determining headcount accurately and setting up a data collection system are among the most urgent steps.
The directive applies to all employers, regardless of sector or size. The pay reporting obligation, however, is linked to headcount thresholds. Employers with more than 250 workers must report annually from June 7, 2027; companies with 150 to 249 workers every three years from the same date; and employers with 100 to 149 workers every three years from 2031. Headcount must be assessed based on the average statistical headcount for the relevant year, so it is advisable to determine which category an employer falls into.
The reports will need to show the gender pay gap in detail, including the average and median gaps, differences in complementary or variable pay, the distribution of female and male workers across quartile pay bands, and a breakdown by worker category. The basis for comparison is gross annual pay: not only basic salary, but also cash and in-kind benefits linked to the employment relationship are relevant.
The directive also affects recruitment. Applicants must be informed of the initial pay or pay range for the position, and employers are prohibited from asking about previous pay. Employers must also ensure that job vacancy notices, job titles and pay-setting criteria are gender-neutral. Employers should, therefore, review their recruitment policies, processes and practices, with the involvement of HR, to ensure compliance.
Workers will also gain new rights. They may request information on their individual pay level and on the average pay levels, broken down by sex, for workers performing the same work or work of equal value. The employer must reply within two months and must inform workers annually of this right. Workers may disclose their own pay, requiring employers to remove any contractual restrictions on such disclosures.
Companies, therefore, need not only to generate the relevant data but also to put in place internal procedures that can handle such requests quickly and lawfully.
One key element of the directive is the joint pay assessment. If pay reporting shows that, within a given category of workers, there is a difference of at least 5% in the average pay level of female and male workers, and the employer cannot justify that difference on objective grounds and fails to remedy it within six months, it must carry out a joint pay assessment in cooperation with workers’ representatives.
The risks do not end with reporting and compliance obligations. If an employer fails to comply with the transparency rules, the burden of proof in later litigation may shift to the employer. The directive also strengthens the workers’ position on legal costs: even if the employer succeeds in court, the court may decide that the worker should not bear the costs of the proceedings if there were reasonable grounds for bringing the claim.
Employers need not necessarily redesign everything from scratch. If the existing job evaluation system meets the requirements of equal treatment and is based on objective, gender-neutral criteria, it may be sufficient to review and document it rather than replace it entirely. The key task in the coming months will be putting internal systems in order. By the time the Hungarian rules are adopted, companies whose internal processes work in practice may be in the strongest position.
This article was first published in the Budapest Business Journal print issue of April 24, 2026.
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