On 7 June 2026 the deadline expired for EU Member States to transpose Directive (EU) 2023/970 — the pay transparency directive — into national law. Bulgaria is still in the process of transposition, but the direction is clear: pay ceases to be a secret negotiated case by case and becomes a process built on objective, documented and gender-neutral criteria.
This is not another box-ticking EU directive. It reorders the way every employer — from a five-person start-up to a 500-strong factory — advertises roles, interviews candidates and justifies pay differences. The sanctions are still being finalised, but the hiring obligations already apply with no company-size threshold.
Why now — and why the pay gap is wider than it looks
The principle of equal pay has been in the EU Treaties since 1957. Seventy years later the gap persists — not for lack of law, but for lack of transparency. This Directive attacks precisely that gap.
Source: Eurostat / National Statistical Institute; impact assessment of the bill amending the Protection Against Discrimination Act.
Who is affected and what changes immediately
The Directive covers both the private and the public sector. There are two distinct regimes with very different timelines — and this is the first thing most employers get wrong:
- The hiring obligations apply to every employer — with no headcount threshold. They are effectively in force already, while transposition is still under way.
- The mandatory reports to the Commission for Protection against Discrimination apply only to employers with 100 or more employees, and in phases (see the timeline table below).
Six concrete changes that affect the daily work of every HR team and every managing director:
- Transparency in hiring — a mandatory starting salary range in the job advert or before the interview.
- No questions about pay history — the employer may not ask a candidate what they earned previously.
- Right to information — an employee may request the average pay levels by gender for work of equal value; the answer must arrive within a set deadline.
- No pay secrecy clauses — clauses preventing employees from discussing their pay with each other are prohibited.
- Documented criteria — employees must have easy access to the criteria used to set pay, pay rises and career progression.
- Reporting for 100+ employees — mandatory reporting by gender; where a gap of 5% or more has no objective justification, a joint pay assessment follows.
The timeline — who reports when
| Date / period | What happens |
|---|---|
| 7 June 2026 | Deadline for transposing the Directive into national law across the EU |
| 2026 | First reference year — the pay data is already being collected now |
| 7 June 2027 | First mandatory reports: employers with 150+ employees |
| 2031 | First mandatory reports: employers with 100–149 employees |
| < 100 employees | Voluntary reporting; the hiring obligations apply in full |
| Gap ≥ 5% | If unjustified — a mandatory joint pay assessment with employee representatives |
| Correction | Unjustified gaps must be corrected within one year of the assessment |
What is specific about the Bulgarian bill
Transposition in Bulgaria runs through a bill amending the Protection Against Discrimination Act, tabled by the Ministry of Labour and Social Policy on 19 May 2026. Three things make the Bulgarian version different from the general framework of the Directive:
- The Commission for Protection against Discrimination is the competent authority. The Commission for Protection against Discrimination will collect the reports, publish the data and provide methodological guidance — not the Labour Inspectorate, which is where most international templates wrongly point.
- Different criteria for “work of equal value”. Instead of the Directive’s wording “skills and effort”, the Bulgarian bill introduces a more granular framework — complexity and heaviness of work, responsibilities and working conditions.
- No 50-employee exemption. The derogation the Directive permits for companies with fewer than 50 employees has not been taken up in the Bulgarian bill — the hiring criteria apply to absolutely every employer.
| Deadline | Obligation |
|---|---|
| 14 days | Information on the average pay level for the same job level |
| 14 days | A reasoned written response where the information provided is incomplete |
| by 31 January | Annual notification to employees of their right to information |
| 1 month | Additional information on a reported gap |
| 1 year | Correction of unjustified gaps following a joint assessment |
How “work of equal value” is scored — the methodology in brief
The hardest practical question is not legal but methodological: how do you objectively compare an accountant with an IT administrator, or with an operations manager? The Directive requires the system to be built on four objective, gender-neutral factors:
| Factor | Weight | What it covers |
|---|---|---|
| Complexity / Skills | 40% | Education, professional experience, problem solving, planning, communication |
| Responsibility | 30% | For people and management, financial resources, information and data, materials |
| Effort / Demands | 20% | Mental and concentration load, emotional effort, physical effort |
| Working conditions | 10% | Physical and psychological environment, work schedule |
Each sub-factor is scored on a scale from 0 to 5, the results are weighted by formula, and each role receives a score from 0 to 100 points. Roles are then grouped into categories (grades) in 10-point bands — the approach recommended by the European Institute for Gender Equality (EIGE). Two completely different jobs with the same score fall into the same category of “work of equal value” — and it is precisely for those that the law requires a pay comparison by gender.
A worked example: what the numbers show for 15 employees
To keep this concrete rather than abstract, we built a full worked example with 15 employees across departments: accounting, IT, operations, HR and administration. Scoring them with the methodology above produces the following results for the mandatory indicators:
The last figure is the most telling: in the example, women are concentrated in the middle pay levels and men in the upper ones. This is exactly the “signal” that demands an explanation in a report to the Commission. The full methodology, every calculation step by step and the 15-employee table are in the presentation below.
📊 Full presentation: 21 slides, 8 steps, a ready-made methodology
Job scoring, categorisation and coding of the workforce, and the calculation of all seven indicators — with a worked example traceable from start to finish. The final slide summarises how we can help: a free consultation, an audit of your current pay by gender, or a full build of processes and procedures — depending on your company’s situation.
An eight-step plan — from job roles to the mandatory reports
- Inventory — map every role, including vacant and seasonal positions.
- Precise criteria — define the four factors and their sub-factors for your organisation.
- Level scale — score on levels 0–5 with concrete, measurable descriptions for each level.
- Weights and points — apply the formula to produce a score for each role.
- Scoring — a score from 0 to 100 points for each job.
- Categories and codes — group roles into grades in 10-point bands.
- Gender-neutrality check — compare pay by category and gender, and document every decision.
- Reporting — calculate the seven mandatory indicators for the Commission.
Steps 1–6 build the job evaluation system. Step 7 makes it defensible before an audit and a court. Step 8 produces the reports themselves.
What to do now, before it becomes urgent
2026 is already the first reference year — the data you fail to collect now, you will not have for the first report in 2027 or 2031, depending on your size. And because there is no headcount threshold for hiring, the obligations on advertising roles and interviewing candidates apply to you whether you have 3 employees or 300.
The most common mistake we see: companies wait for the final text of the law before doing anything at all. The problem is that the job evaluation system — the inventory of roles, the criteria, the scoring — is independent of the final sanctions and can be built today. When the law enters into force, you already have the data instead of starting to collect it under pressure.
Frequently asked questions
Who does Directive (EU) 2023/970 apply to?
Both the private and the public sector, without exception. The hiring obligations apply to every employer, with no headcount threshold. The mandatory reports apply to employers with 100 or more employees.
When does the Directive take effect in Bulgaria?
The transposition deadline was 7 June 2026. The process runs through the bill amending the Protection Against Discrimination Act, tabled by the Ministry of Labour and Social Policy. 2026 is the first reference year.
When is the first report due?
Employers with 150+ employees — by 7 June 2027. Employers with 100–149 employees — by 2031. Under 100 employees — reporting is voluntary, but the hiring obligations apply in full.
What is “work of equal value”?
Roles with an identical or near-identical score under a system of objective, gender-neutral criteria — regardless of function. Two entirely different jobs can fall into the same category if they carry the same number of points.
What happens if the gap exceeds 5%?
If the gap in a given category is 5% or more and cannot be objectively justified, a mandatory joint pay assessment with employee representatives follows, and the gap must be corrected within one year.
Can we ask a candidate about their previous salary?
No. It is prohibited. The employer must also disclose a starting salary range in the job advert or before the interview.
Do not wait for the final text of the law to start
Fin Logic helps companies prepare for Directive 2023/970 in three ways — a free consultation, an audit of your current pay by gender, or a full build of processes and procedures (job register, scoring, the mandatory reports). Everything is tailored to your headcount and the scope of the project — there is no standard price list.
Book a free assessment →☎ +359 883 300 850 (Viber: message) · ✉ office@finlogic.bg