Cyprus Pay Transparency Law: EUPTD Transposition Status
Local term: μισθολογική διαφάνεια
As of 28 September 2026: Cyprus has published a draft transposition law. A revised draft followed the consultation that closed in December 2025, and the bill is awaiting Council of Ministers approval before going to the House of Representatives.
Status snapshot
| Status | Draft published |
|---|---|
| National instrument | Draft law on strengthening equal pay through pay transparency and enforcement mechanisms (2026). |
| Official source | Draft bill text (Department of Labour Relations, Ministry of Labour and Social Insurance) |
Pay gap reporting required before the Directive
No national gender pay gap reporting obligation before the Directive.
When Directive (Article 9) pay gap reporting starts
Article 9 reporting covers seven indicators: the mean and median gender pay gap, the mean and median gap in variable pay, the proportion of women and men receiving variable pay, the proportion of women and men in each pay quartile, and the gender pay gap by category of workers.
| Employees | First report | Frequency |
|---|---|---|
| 250+ | 7 June 2027 (2026 data) | Annually |
| 150–249 | 7 June 2027 (2026 data) | Every three years |
| 100–149 | 7 June 2031 (2030 data) | Every three years |
| Under 100 | No obligation | Voluntary |
As set out in the draft bill (Article 10). Other duties, including the pay secrecy ban, are not phased in separately: they take effect as soon as the law is published in the Official Gazette, whenever that happens, while only the reporting deadlines above are tied to future dates.
Employee right to request pay information
As set out in the draft bill (Article 8), this right is not phased in separately either: it takes effect as soon as the law is published in the Official Gazette, whenever that happens. Employers have up to two months to respond.
What remains unclear
Information is unclear on the anonymity threshold for identifying pay data by job category, and on the methodology employers should use for job evaluation, which the draft leaves to agreement between employer and employee representatives. The exact date the bill will be enacted is also not yet set, as it is still awaiting Council of Ministers approval before going to the House of Representatives.
Things to work on now
- Priority for Cyprus. Unusually, the draft makes non-compliance a criminal offence, with a fine of up to €10,000 or up to six months' imprisonment, and extends personal liability to company directors and officers. Treat this as a governance issue for leadership, not only an HR one.
- Priority for Cyprus. If your gender pay gap in any employee category is 5% or more and cannot be justified on objective grounds, you have six months from submitting your Article 9 data to correct it before a joint pay assessment is triggered. Start monitoring gaps by category now so you are not caught out.
- Map the draft. Compare the published draft with your current practice and note where it goes further than the Directive.
- Job architecture. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4). This is needed whatever the final text says.
- Pay ranges. Agree pay ranges for roles so you are ready for pre-employment disclosure (Article 5).
- Clean your data first. Article 9 reporting is only as good as the pay data behind it. Prioritise getting records complete and consistently structured by gender, job category and pay component, so a trial calculation is meaningful.
- Shadow reporting. Run a trial gender pay gap calculation on 2026 data using the Directive's Article 9 indicators, including by category of workers.
- Remediation budget. Model the cost of closing unexplained gaps of 5% or more, which would trigger a joint pay assessment (Article 10).
Legislative timeline
- November 2025Draft published for consultation
- 4 December 2025Consultation closes
- January 2026Revised draft published
Frequently asked questions
Has Cyprus transposed the EU Pay Transparency Directive?
Cyprus has published a draft transposition law. A revised draft followed the consultation that closed in December 2025, and the bill is awaiting Council of Ministers approval before going to the House of Representatives.
When does gender pay gap reporting start in Cyprus?
Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Cyprus.
What should employers in Cyprus do now?
The draft asks for weighted job evaluation criteria and up to four years of pay data on request. Check your historic pay data is retrievable. Compare the published draft with your current practice and note where it goes further than the Directive. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4). This is needed whatever the final text says.