Loontransparantie: wat uw eigen land vraagt, en wanneer

The law and its gazette reference are certain; its text is not. Three official routes refuse an automated client, and the only reachable copy is a subscription publisher. A deadline nobody can open is worse than no deadline.

• The reporting article applies only to employers with at least 100 employees (Article 9(8)), so below that there is no Italian reporting duty at all rather than a voluntary one.
• An employer with a single group pay policy may report aggregated at national level where that represents the data more reliably (Article 9(3)).
• The Ministry of Labour collects the data; the employer does not publish it. Article 9(4) leaves the mechanism to ministerial decrees, due within ninety days of 7 June 2026. They may take the data from INPS, INAIL and the labour inspectorate, so what an employer sends is set by them.

• The first report covers calendar year 2026 for both reporting bands (regulation 9(2) and 9(3)). The pay data being collected this year is what that report is made from.
• The second report for the 150 to 249 band covers 2029 and not 2028, which is what three-yearly means once the first period is fixed (regulation 9(3)).
• Regulation 9(5) wants every report submitted within fourteen working days of the yearly period's end. That falls far earlier than the 7 June dates in the same regulation. Both are in the act; plan for the earlier one.

• Slovakia merges the Directive's two middle bands: one three-yearly duty for 100 to 249 employees, and an annual one at 250 and above (Section 14(2) and (3)).
• The annual deadline is 15 April of the following calendar year, a month the Directive does not mention (Section 14(2)).
• An employer with at least 150 employees reports first by 7 June 2027, for 1 August to 31 December 2026 only (Section 18(3)). One with 100 to 149 reports first by 7 June 2031, for 2030 (Section 18(4)).
• An employer established before 7 June 2026 had to have its pay structure in place by 31 July 2026 (Section 18(1)). That date has passed, and no date in the Directive says so.
• Below 100 employees a report may be provided and is not required (Section 14(4)).