<\/p>\n
It is understandable that many owners and managers of Hungarian small and medium-sized enterprises (SMEs) see the EU Pay Transparency Directive ((EU) 2023\/970, the \u201cDirective\u201d) as one more administrative burden. In practice, it is mostly a matter of organising what a well-run company should already have: clear, documented and fair rules on pay. Companies that start early can manage the new requirements comfortably and even turn them into a recruitment advantage.<\/p>\n
Key takeaways<\/strong><\/p>\n Do we have to wait for the Hungarian law?<\/strong><\/p>\n Many business leaders assume that nothing applies until the national law is adopted. That is not entirely risk-free.<\/p>\n After the transposition deadline has passed, Hungarian courts must interpret existing national law, including the Labour Code\u2019s rules on equal treatment and equal pay for equal work or work of equal value, as far as possible in line with the wording and purpose of the Directive.<\/p>\n It is equally important to understand the limits of this principle:<\/p>\n The real exposure today comes from rules that already apply<\/strong>. Equal pay for equal work, or work of equal value, is already mandatory in Hungary. The burden of proof is also already shared in employees\u2019 favour: if an employee shows that they were disadvantaged and had a protected characteristic at the time, such as sex, the employer must prove that the alleged circumstances did not exist or that it complied with the equal treatment requirement. In a pay discrimination lawsuit, this is where the risk lies.<\/p>\n Which requirements will affect SMEs?<\/strong><\/p>\n The detailed reporting rules hit larger employers first, as the table shows. This article focuses on SMEs, but note that employers with at least 250 employees will have annual reporting duties from 2027.<\/p>\n The Hungarian act may extend reporting duties to smaller employers, so the final details may differ.<\/p>\n Regardless of company size, the Directive requires the following. These become binding once the Hungarian implementing law enters into force, and the details may vary in the national rules.<\/p>\n This does not entitle anyone to see a colleague\u2019s individual salary. The employer must reply within a reasonable time, and no later than two months<\/strong>. Employers must also inform employees about this right every year.<\/p>\n How can an SME prepare?<\/strong><\/p>\n For most companies this is a structured organising exercise rather than a revolution. We suggest three steps.<\/p>\n Step 1: Job evaluation and pay audit.<\/strong> Using the Directive\u2019s objective criteria (skills, effort, responsibility and working conditions), identify which roles count as the same or of equal value. Then review current pay to find unjustified differences between women and men doing the same or equal-value work.<\/p>\n Step 2: Put the rules in writing.<\/strong> Document the objective, gender-neutral criteria (experience, qualifications, performance) that determine pay and pay rises, and apply them consistently. This strengthens your position in a dispute: if an employee makes a plausible case of discrimination, the employer has to prove that a pay difference rests on objective grounds. Under the Directive, if an employer has failed to meet its transparency obligations, the burden of proof also lies with the employer, subject to a narrow exception.<\/p>\n Step 3: Update your documents and train your people.<\/strong> Remove clauses banning pay disclosure from employment contracts, review job ad and application templates, and prepare HR staff for a new type of interview.<\/p>\n If an external adviser coordinates the process, the workload for management stays low and compliance can be built without disrupting daily operations. An SME with a clear and transparent pay system will also find it easier to attract and keep good employees than its competitors.<\/p>\n Frequently asked questions<\/strong><\/p>\n Does the Pay Transparency Directive apply to small companies in Hungary?<\/strong> Is the Directive already in force in Hungary?<\/strong> Can we still ask candidates about their previous salary?<\/strong> Can employees see each other\u2019s salaries?<\/strong> What is the best protection against pay discrimination claims?<\/strong> What to watch next<\/strong><\/p>\n The Hungarian implementing act is still pending, and the final rules may differ from the Directive\u2019s baseline in several details. Our firm is monitoring the legislative process and will publish a practical guide once the text is adopted. In the meantime, do not leave preparation to the last minute. Review your internal processes now, so that when the Hungarian law takes effect, your company already has its answers and systems in place.<\/p>\n","protected":false},"excerpt":{"rendered":" It is understandable that many owners and managers of Hungarian small and medium-sized enterprises (SMEs) see the EU Pay Transparency Directive ((EU) 2023\/970, the \u201cDirective\u201d) as one more administrative burden. In practice, it is mostly a matter of organising what a well-run company should already have: clear, documented and fair rules on pay. Companies […]<\/p>\n","protected":false},"author":4,"featured_media":29539,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_et_pb_use_builder":"","_et_pb_old_content":"","_et_gb_content_width":"","footnotes":""},"categories":[50],"tags":[],"class_list":["post-29542","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-employment"],"yoast_head":"\n\n
\n
\n\n
\n Employer size<\/strong><\/td>\n First pay gap report under the Directive<\/strong><\/td>\n Frequency<\/strong><\/td>\n<\/tr>\n<\/thead>\n\n \n 250+ employees<\/td>\n 7 June 2027<\/td>\n Annually<\/td>\n<\/tr>\n \n 150\u2013249 employees<\/td>\n 7 June 2027<\/td>\n Every three years<\/td>\n<\/tr>\n \n 100\u2013149 employees<\/td>\n 7 June 2031<\/td>\n Every three years<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n \n
\n
\n
\nYes, in part. Recruitment transparency, the ban on pay history questions, the end of pay secrecy clauses and the employee right to pay information apply regardless of company size once Hungarian law implements them. The detailed pay gap reporting applies first to employers with 100 or more employees, though Hungary may go further.<\/p>\n
\nThe transposition deadline expired on 7 June 2026, but Hungary\u2019s implementing law had not been published at the time of writing. Until then, existing Hungarian equal treatment and equal pay rules, and the existing rules on the burden of proof, remain the main source of legal risk.<\/p>\n
\nUnder the Directive this will be prohibited once Hungarian law implements it. It is sensible to stop now and to train interviewers accordingly.<\/p>\n
\nNo. Employees will be entitled to their own pay level and to average pay levels by sex for comparable roles, not to individual colleagues\u2019 pay.<\/p>\n
\nA documented pay system built on objective, gender-neutral criteria and applied consistently.<\/p>\n