- The EU transposition deadline was 7 June 2026. Hungary missed it.
- As far as we are aware, no Hungarian transposing act has been promulgated yet.
- The Government's autumn 2026 legislative programme lists a bill on the transparency of pay between men and women (submission planned: September; adoption requested: October 2026).
- The reporting deadlines are fixed by the Directive: 7 June 2027 for 150+ employees, 7 June 2031 for 100-149.
Where does Hungary stand?
Directive (EU) 2023/970 required every Member State to transpose it by 7 June 2026. Hungarian HR media confirmed that this did not happen by the deadline (HR Portál), and as of 10 October 2026 we are not aware of any promulgated Hungarian act.
The most concrete official signal is the Government's legislative programme for the autumn 2026 parliamentary session. Item 12 is a bill titled (our translation) “on the transparency of pay between men and women and on amending certain related acts”. The presenting minister is the Minister for Social Affairs and Family; submission was planned for September and adoption is requested for October 2026. A cross-border tracker by Ius Laboris (30 September 2026) accordingly moved Hungary from “no activity” to “initial steps” (source).
Two practical takeaways for international HR teams:
- Hungary is drafting a stand-alone act on pay transparency (plus amendments to related laws), not only a Labour Code amendment.
- The details that matter for your rollout (entry-into-force date, any transition period, reporting below 100 employees, the enforcement authority and fine levels) are not public yet. Plan to the Directive's minimum and adjust when the text is published.
What applies until the Hungarian law is adopted?
Equal pay is already law in Hungary: Section 12 of the Hungarian Labour Code (Act I of 2012) requires equal treatment, in particular with regard to pay, and lists the criteria of work of equal value. Courts must interpret national law in line with the Directive. The new procedural obligations (pay ranges for applicants, the salary history ban, pay reporting) generally cannot be enforced directly against a private employer before transposition; vis-à-vis public sector employers, direct effect of sufficiently precise provisions may be argued, which Hungarian trade unions are already doing (SZEF, 20 September 2026).
Obligations by company size (Directive minimum)
| Obligation (Article) | <50 | 50-99 | 100-149 | 150-249 | 250+ |
|---|---|---|---|---|---|
| Pay or pay range to applicants before the interview (5) | yes | yes | yes | yes | yes |
| Ban on asking about salary history (5) | yes | yes | yes | yes | yes |
| Pay setting and progression criteria accessible (6) | yes* | yes | yes | yes | yes |
| Right to information, reply within 2 months (7) | yes | yes | yes | yes | yes |
| Gender pay gap reporting (9) | no** | no** | from 2031, every 3 yrs | from 2027, every 3 yrs | from 2027, annually |
| Joint pay assessment if unexplained gap of 5%+ (10) | no | no | yes | yes | yes |
* Member States may exempt employers with fewer than 50 workers from the pay progression criteria (Art. 6(2)). ** Member States may require reporting below 100 workers (Art. 9(5)); whether Hungary will do so is not yet known.
Timeline
- 6 June 2023: Directive enters into force (published in OJ L 132 on 17 May 2023).
- 7 June 2026: transposition deadline (missed by Hungary).
- Autumn 2026: Hungarian bill planned (submission: September, adoption: October).
- 7 June 2027: first reports for 250+ (covering calendar year 2026) and 150-249 employees.
- 7 June 2031: first reports for 100-149 employees.
What to do now if you employ people in Hungary
- Secure your 2026 pay data. For 250+ entities, the first report (due 7 June 2027) covers 2026. Check that you can break it down by gender, worker category, base pay and variable components.
- Map Hungarian roles into your job architecture. “Work of equal value” must be assessed with objective, gender-neutral criteria (skills, effort, responsibility, working conditions; Art. 4).
- Prepare pay ranges for Hungarian vacancies in gross monthly HUF, and remove salary history questions from HU application forms and agency briefs.
- Plan employee communication in Hungarian, including the annual notice about the right to request pay information (Art. 7(3)).
- Brief local managers. Questions about pay will reach them first.
Frequently asked questions
Has Hungary transposed the EU Pay Transparency Directive?
Not as of 10 October 2026, as far as we are aware. The transposition deadline was 7 June 2026. The Hungarian Government's autumn 2026 legislative programme lists a bill on the transparency of pay between men and women, with submission planned for September and adoption requested for October 2026.
When is the first pay gap report due in Hungary?
The Directive itself sets the dates: employers with 250 or more workers and employers with 150-249 workers must report by 7 June 2027; employers with 100-149 workers by 7 June 2031. Employers with 250+ workers report annually (the first report covers calendar year 2026), the others every three years.
Do Hungarian job ads have to include a salary range?
Under the Directive, applicants must receive the initial pay or pay range before the job interview, for example in the job ad. Asking about salary history is prohibited. In Hungary these rules become enforceable once the national law enters into force; the exact date is not yet known.
Which law applies to our Hungarian subsidiary?
Employees working in Hungary will be covered by the Hungarian transposing act. Until it is adopted, the Hungarian Labour Code's equal pay rule (Section 12) applies, interpreted in line with the Directive.
Hungarian deep dives
Our detailed guides are in Hungarian (browser translation works well):
Sources
- Directive (EU) 2023/970, official text: EUR-Lex
- Hungarian Government, autumn 2026 legislative programme, annex 1, item 12 (in Hungarian): parlament.hu (PDF)
- Ius Laboris, 30 September 2026: which countries have transposed
- HR Portál, July 2026 (in Hungarian): pay transparency Q&A
- SZEF trade union forum, 20 September 2026 (in Hungarian): statement
- Hungarian Labour Code, Section 12 (in Hungarian): njt.hu
Need a local partner for the Hungarian rollout?
Y2Y Ltd. is a Budapest-based leadership and organisational development company. Together with partner employment lawyers we support international HR teams with pay audits, job evaluation, pay ranges and manager communication for Hungarian entities, in English and Hungarian.