Portugal Pay Transparency Law: EUPTD Transposition Status
Local term: transparência remuneratória
As of 28 September 2026: Portugal published a draft bill for partial transposition on 5 August 2026, amending Law 60/2018. The shortened public consultation ended on 25 August 2026. The bill still needs parliamentary approval.
Status snapshot
| Status | Draft published |
|---|---|
| National instrument | Draft government bill for partial transposition amending Law 60/2018, published in Separata No. 26 of the Boletim do Trabalho e Emprego. |
| Official source | Draft bill: Boletim do Trabalho e Emprego, Separata No. 26/2026 (PDF) |
Pay gap reporting required before the Directive
Relatório Único and pay difference evaluation
| Who reports | All employers report. Employers with 50+ employees can be notified by the labour inspectorate (ACT) |
|---|---|
| How often | Annually. A notified employer has 120 days to submit an evaluation plan |
| What is reported | Pay by sex, job category and qualification level. Where ACT identifies unjustified differences, a plan to evaluate them |
| Published or internal | Submitted to the authorities. Not published by the employer |
| Legal basis | Law 60/2018 |
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 Portugal. Law 60/2018 already requires gender-neutral job evaluation. Check yours is documented and current.
- 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).
- 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
- 5 August 2026Draft bill published (BTE Separata No. 26)
- 25 August 2026Consultation closes
Frequently asked questions
Has Portugal transposed the EU Pay Transparency Directive?
Portugal published a draft bill for partial transposition on 5 August 2026, amending Law 60/2018. The shortened public consultation ended on 25 August 2026. The bill still needs parliamentary approval.
When does gender pay gap reporting start in Portugal?
Some reporting already applies under national law: all employers report pay by sex in the annual Relatório Único, and employers with 50+ employees notified by the labour inspectorate must submit a plan to evaluate pay differences. Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Portugal.
What should employers in Portugal do now?
Law 60/2018 already requires gender-neutral job evaluation. Check yours is documented and current. 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.