Finland publishes Pay Transparency legislation
Finland has now published its long-awaited legislation implementing the EU Pay Transparency Directive, providing employers with greater certainty around reporting obligations, employee rights, and compliance timelines.
Although Finland missed the original 7 June 2026 transposition deadline, the Government submitted Bill HE 129/2026 to Parliament on 9 July 2026, setting out a clear roadmap for implementation.
For employers operating in Finland, the focus now shifts from preparation to planning for the new requirements coming into force from 1 January 2027.
Implementation Timeline
The Finnish Government has proposed the following implementation schedule:
- 9 July 2026 – Government Bill (HE 129/2026) submitted to Parliament
- 1 January 2027 – New legislation enters into force
- 2 May 2028 – First gender pay gap reporting deadline for employers with 150+ employees (covering 2027 data)
- May 2031 – First reporting deadline for employers with 100–149 employees (covering 2030 data)
Unlike the original Directive, Finland will not require reporting on 2026 payroll data, shifting the first reporting year to 2027.
What Makes Finland's Approach Different?
1. Statistics Finland Calculates Most Pay Gap Metrics
Finland has introduced a distinctive reporting model.
Rather than calculating organisation-level gender pay gap indicators themselves, employers with 100 or more employees will submit payroll information through the Incomes Register.
Additional payroll information will become mandatory, including:
- Hours worked
- Full-time or part-time status
- Variable pay components
Statistics Finland will calculate six of the seven required gender pay gap indicators and provide the results to the Equality Ombudsman.
Employers will only calculate the category-level gender pay gaps, making high-quality payroll data and clear job classifications essential.
2. Employee Right to Pay Information Applies to Every Employer
From 1 January 2027, every employee in Finland, regardless of employer size, will have the right to request:
- Their own pay level
- Average pay levels for employees performing the same or equivalent work
- Pay information broken down by gender
Employers must respond within two months.
This means organisations should define comparable employee groups before the legislation comes into force.
3. Privacy Protection for Small Comparison Groups
Where providing average pay data could identify an individual employee, the information will instead be shared with:
- An employee representative, or
- The Equality Ombudsman
While the legislation references five employees as an indicative statistical minimum, there is no fixed threshold, allowing assessments to be made case by case.
4. Existing Equality Requirements Continue
The new reporting requirements do not replace Finland's existing obligations.
Organisations with 30 or more employees must still maintain:
- Equality Plans
- Pay Surveys
These existing requirements will operate alongside the new EU Pay Transparency reporting obligations.
Recruitment Transparency
The legislation also strengthens transparency during recruitment.
Employers will be expected to:
- Provide salary information before or during recruitment
- Avoid requesting salary history from candidates
A proposal requiring gender-neutral job advertisements and job titles was not included in the final bill following consultation.
Gender Pay Gap Reporting
Employers with 100 or more employees will become subject to gender pay gap reporting.
The phased implementation is:
- 150+ employees: first report due May 2028 (2027 payroll data)
- 100–149 employees: first report due May 2031 (2030 payroll data)
Where an unexplained gender pay gap of 5% or more exists, employers may still be required to conduct a joint pay assessment with employee representatives.
What This Means for Payroll Teams
Payroll teams will play a central role in compliance.
Organisations should begin preparing by ensuring they have:
- Accurate payroll data
- Clearly defined comparable roles
- Reliable reporting processes
- Strong audit trails
- Payroll systems capable of capturing additional Incomes Register data
Employers operating across multiple countries will also need consistent global payroll reporting and governance.
How Employers Can Prepare Now
To prepare for the new Finnish legislation, organisations should:
- Review pay structures and progression criteria
- Define comparable employee groups
- Assess gender pay gaps proactively
- Improve payroll data quality
- Prepare payroll systems for new Incomes Register reporting fields
- Align HR, Payroll and Legal teams on compliance
Starting preparations now will help employers meet the new requirements efficiently once the legislation takes effect in January 2027.
