In the meantime, while domestic regulation is still pending, employers can begin preparing. It is certain that Hungarian law will transpose at least the minimum standards set out in the directive, hopefully with no more than a few months’ delay. The Hungarian legislator cannot adopt more lenient rules than those required by the directive, although it may introduce stricter requirements. Employers can, therefore, already begin applying the core principles, reviewing their compensation systems, and implementing the necessary adjustments to ensure future compliance.
A practical starting point for preparation is for employers to familiarize themselves with the methodologies developed by the Court of Justice of the European Union and national courts in recent years for comparing the value of different roles.
“Applying these best practices can help prevent discrimination-related disputes and ensure that companies are well prepared for the introduction of domestic regulation,” says Adrienn Orosz, attorney-at-law, and head of the employment law group at LeitnerLaw.
Under the directive, pay structures must be designed to assess whether employees are in comparable positions based on objective, gender-neutral criteria. Employers must establish a job classification grading system in which employees performing work of equal value are grouped into the same category and then assign pay ranges to these levels. A single grade may include multiple different roles and positions. It is important to note, however, that pay differences may still exist within the same category: key is that it must be supported by objective justification.
Evaluations must remain unbiased: subjective managerial judgment should not distort outcomes, even if certain roles have traditionally been regarded as more valuable. According to EU guidance, at least four key factors should be evaluated: skills, effort, level of responsibility, and working conditions.
“A legally robust, objective pay structure rests on a company competency framework that defines the skills and capabilities required for each role. This provides the foundation for building a comprehensive job architecture,” Orosz emphasizes.
A notable example of a detailed evaluation framework is the litigation brought against clothing retailer Next, where more than 3,500 female retail employees claimed they were unjustifiably paid less than male warehouse workers. The court was tasked with determining whether retail and warehouse roles were of equal value. In doing so, it examined a wide range of criteria, including required knowledge, planning and organizational duties, responsibility for equipment and safety, communication and customer interaction, training responsibilities, as well as mental and physical demands and working conditions.
Each factor was assigned expectation levels and point values, leading to the conclusion that the roles were indeed of equal value. The court found the company had unlawfully paid higher wages to warehouse workers and ordered it to revise its pay policy and pay the claimants approximately GBP 30 million (around HUF 13 billion) in back pay. The case highlights the significant financial and reputational risks involved for employers.
The consequences of discrimination can be severe. Employees may be entitled to compensation without an upper limit of up to 3 years. In addition, employers may face proportionate, effective, and dissuasive fines.
LeitnerLaw and LeitnerLeitner, through their employment advisory business unit, have developed an integrated approach that examines employment issues holistically. This model provides clients with access to comprehensive expertise through a single point of contact, resulting in fewer coordination efforts, reduced risk, and greater focus.
This article was first published in the Budapest Business Journal print issue of June 19, 2026.
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