Pay Transparency: What Employers Need to Know

Starting January 1, 2027, employers face new requirements related to pay transparency. Employers will be required to submit monthly data to „Sodra“ regarding employee remuneration and working hours, and pay gap indicators will be calculated for larger companies.

The new requirements aim to guarantee employees' right to equal pay for equal work or work of equal value, increase transparency in remuneration setting, and reduce the gender pay gap.

1. WHEN DO THE NEW PAY TRANSPARENCY REQUIREMENTS COME INTO EFFECT?

The new description of the procedure for collecting and publishing employee information to implement the right to fair remuneration and general pay evaluation was approved on July 17, 2026 by order of the Minister of Social Security and Labour, and entered into force on July 31, 2026.

Key dates for employers:

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• By December 31, 2026 – adopt a remuneration system or review and, if necessary, update the existing policy;
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• From January 1, 2027 – mandatory submission of SDUP (Transparent Remuneration Reports) to „Sodra“ begins;
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• By February 28, 2027 – initial submission of data for the month of January 2027;
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• From March 1, 2027 – employees gain the right to request specific information about their remuneration and the remuneration of employees in the same job category;
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• From March 1, 2028 – employee information rights are further expanded.

2. WHAT DATA WILL HAVE TO BE SUBMITTED?

From January 1, 2027, employers must submit a monthly Transparent Remuneration Report (SDUP) via the Electronic Insured Services System (EDAS).

The report must be submitted by the last day of each month for the preceding month.

Every month, employers will need to submit:

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• gross monthly base remuneration accrued for the employee;
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• gross supplementary monthly remuneration accrued for the employee;
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• the employee's paid working time in hours.

For the initial submission, the following additional information is required:

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• standard working time rate of the employee;
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• working time schedule / regime;
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• the employee's job category defined in the company's remuneration system.

This initial data will only need to be updated if changes occur.

3. WHAT WILL „SODRA“ CALCULATE BASED ON THE SUBMITTED DATA?

Based on employer submissions, „Sodra“ will calculate monthly indicators no later than the 15th day of the current calendar month for the month before last (for the first time – on March 15, 2027) and provide them to employers, the State Labour Inspectorate, and the Office of the Equal Opportunities Ombudsperson:

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• average hourly gross remuneration of each employee;
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• average hourly remuneration of men and women in each job category;
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• average hourly base remuneration of each employee;
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• average hourly base remuneration of men and women by job category;
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• average hourly supplementary remuneration of each employee;
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• average hourly supplementary remuneration of men and women by job category.

In addition, „Sodra“ will calculate these indicators annually on a yearly basis, separately detailing the average annual remuneration of men and women in each job category.

This will allow evaluation not only of general employee compensation levels, but also of pay differences by gender and job category.

4. FOR LARGER COMPANIES – PAY GAP ASSESSMENT

For companies with 100 to 249 insured employees, these metrics will be calculated every three years; for companies with 250 or more insured employees – annually.

The following metrics will be evaluated:

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• the gender pay gap;
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• the gender pay gap in supplementary remuneration;
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• the gender median pay gap;
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• the gender median pay gap regarding supplementary remuneration;
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• the proportion of female and male employees receiving supplementary remuneration;
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• the proportion of female and male employees in each pay quartile;
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• the pay gap by base and supplementary remuneration according to job category.

„Sodra“ will provide the initial data by:

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• March 1, 2028 – for companies with 150 or more insured employees;
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• March 1, 2031 – for companies with 100 to 149 insured employees.

5. WHICH REMUNERATION INDICATORS WILL BE MADE PUBLIC?

„Sodra“ will publicly publish the monthly average hourly remuneration of men and women for employers with:

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• at least 8 employees;
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• more than 3 male employees;
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• more than 3 female employees.

Additionally, only key pay gap indicators will be published publicly to provide an overview of the general wage disparity situation.

6. WHAT REMUNERATION INFORMATION CAN AN EMPLOYEE REQUEST?

The new regulations grant employees expanded rights to access remuneration data.

From March 1, 2027

An employee may request their employer, employee representatives, the State Labour Inspectorate, or the Office of the Equal Opportunities Ombudsperson to provide:

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• their own average monthly hourly remuneration;
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• the average hourly remuneration of male and female employees in the same job category.

From March 1, 2028

An employee will additionally be entitled to receive:

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• their own annual remuneration;
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• their own average annual hourly remuneration;
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• the average annual remuneration of all company employees;
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• the average annual hourly remuneration of male and female employees in the same job category.

7. WHAT SHOULD EMPLOYERS PREPARE RIGHT NOW?

By December 31, 2026, employers must adopt a clear remuneration system or review their existing policy.

The remuneration policy must define:

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• objective and gender-neutral criteria;
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• job classification and grouping principles;
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• base remuneration determination criteria;
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• supplementary remuneration rules and allocation procedures.

Employers should assess in advance whether their remuneration framework complies with the new statutory requirements and whether job categories and pay criteria are clearly structured.

8. WHAT DOES THIS MEAN PRACTICALLY FOR YOUR COMPANY?

New pay transparency rules entail more than just an extra monthly report to „Sodra“. Companies must ensure payroll data is tracked properly, job roles are clearly grouped, and pay systems are grounded in objective, gender-neutral principles.

Practical steps to take today:

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• review and update your internal remuneration system;
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• assess job classifications and employee grouping;
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• ensure payroll accounting data is collected in a format ready for SDUP reporting;
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• evaluate base vs. supplementary remuneration data structures;
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• prepare internal procedures for handling employee inquiries regarding pay information.

Meeting pay transparency standards means preparing not only for regulatory reporting, but also establishing a clear, fair, and transparent compensation model across the organization.

If you have any questions regarding updating your remuneration policy or preparing for SDUP reporting, contact your accounting and payroll specialists – we are here to help you navigate these regulatory changes smoothly.