Luxembourg Pay Transparency Law: EUPTD Transposition Status
Local term: transparence salariale
As of 28 September 2026: At last check, Luxembourg had not filed a bill with Parliament. A preliminary draft (avant-projet de loi) was announced in November 2025 and has been under consultation within government.
Status snapshot
| Status | No draft yet |
|---|---|
| National instrument | Preliminary draft bill (avant-projet de loi) under consultation within government. No bill filed with Parliament. |
| Official source | No draft legislation published at last check (28 September 2026). |
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.
Not yet legislated.
Things to work on now
- Priority for Luxembourg. The preliminary draft includes a ban on pay secrecy clauses and a reversed burden of proof. Review contract templates early.
- Use the Directive as your baseline. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted.
- 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).
- Data readiness. Check your HR and payroll systems can produce the Article 9 indicators, including variable pay and gaps by category of workers.
- Contracts and recruitment. Review pay secrecy clauses and pay history questions now, as these changes carry little cost.
- Review date. Set a date to check for a published bill, as national timelines can move quickly.
Legislative timeline
- 19 November 2025Preliminary draft announced
- May 2026Consultation within the Ministry of Labour
- 7 June 2026Transposition deadline missed
Frequently asked questions
Has Luxembourg transposed the EU Pay Transparency Directive?
At last check, Luxembourg had not filed a bill with Parliament. A preliminary draft (avant-projet de loi) was announced in November 2025 and has been under consultation within government.
When does gender pay gap reporting start in Luxembourg?
Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Luxembourg.
What should employers in Luxembourg do now?
The preliminary draft includes a ban on pay secrecy clauses and a reversed burden of proof. Review contract templates early. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4).