Employment Contracts Act Amendments — Estonia's Partial Pay Transparency Transposition

On 17 June 2026, Estonia's Riigikogu adopted amendments to the Employment Contracts Act, approved by the President on 29 June 2026 and published in the State Gazette on 3 July 2026; they entered into force on 13 July 2026. The amendments transpose only the recruitment-transparency strand of Directive (EU) 2023/970: employers must disclose salary information, or the applicable pay range, to job applicants before an interview, and are barred from asking candidates about their current or previous pay. The directive's pay-gap reporting and joint pay-assessment provisions — the mechanisms most directly aimed at closing the gap — remain untransposed; officials cited concerns about the administrative burden these would place on employers, and as of mid-2026 no further draft legislation was before parliament.
The gap this leaves is significant: Estonia recorded the EU's largest unadjusted gender pay gap in 2024, at 18.8%, far above the EU-27 average of 11.1%; the country's own statistics office (Statistikaamet) has found the gap widest in financial and insurance activities. The partial transposition is a cautionary case: it improves transparency at the hiring stage but leaves untouched the structural reporting and audit mechanisms the directive was designed to introduce, with no timeline yet for when — or whether — the remaining provisions will follow.

Read the full analysis: https://arlettipartners.com/estonia-partial-implementation-of-the-eu-pay-transparency-directive/