The directive will affect all employers and employees in the public and private sectors, and specific provisions will also apply to job applicants. Nevertheless, at the time of writing this article, the directive has not yet been transposed into Hungarian law, and no information is available on what draft legislation the committee responsible for transposing the directive, operating under the Ministry of National Economy, has developed to date.
In other words, very little is known in Hungary about the legislator’s plans beyond the minimum requirements set out in the directive. Even in professional forums, those responsible reveal little about the direction of the regulations.
It seems likely that the legislation will meet the minimum standards or only slightly exceed them. We discuss here some expected legislative trends and mention the practices many companies are already applying and the problems they are facing.
Firstly, it is essential to emphasize that employers must have wage structures in place that ensure equal pay for equal work or work of equal value. The concept of “wage structure” is not defined in the directive. It is unclear whether a clear definition can be expected from the Hungarian legislator in this regard, or whether statistical methodological guidelines will be applicable.
The basic function of pay structures will be to enable an assessment of whether employees are in a comparable position in terms of the value of their work, based on i) skills, ii) effort, iii) responsibility and working conditions, and iv) any other factors relevant to the position in question.
The directive may also impact employers’ recruitment processes. Job applicants must be given the right to receive information about the initial remuneration or remuneration range for the position in question and, where applicable, the relevant provisions of the collective agreement.
Although this is already partially implemented in everyday life, it has been rare for job applicants to be familiar with the rules of collective bargaining agreements before they are hired. Further, it will certainly no longer be possible to ask applicants about their current remuneration.
Employers will have to make the criteria used to determine employee remuneration, wage levels, and wage increases easily accessible to their employees. According to the directive, remuneration includes the regular basic or minimum wage or salary, and any other benefits the employee receives from their employer, directly or indirectly (as a supplementary or variable component), in cash or in kind, in respect of their employment. The wage level is the gross annual remuneration and the corresponding gross hourly wage (the latter indicator is particularly relevant when there is no data available for the entire year for an employee).
Because the concept of a “wage” is not defined in the directive, it is expected that it will be in the local legislation. It is currently unclear whether the Hungarian legislator will define guidelines that will enable employers to easily and uniformly express the value of certain in-kind benefits in monetary terms; at this stage, this appears to be a significant problem for companies preparing for the directive.
Employees shall not be prevented from disclosing their remuneration, and it will be prohibited to apply contractual terms that restrict employees from disclosing information about their remuneration. Thus, we believe that to avoid the application of these rules, it may become practice to terminate the employment of senior managers and employ them under civil law contracts, or even to “relocate” their employment to another company within the same company group.
Employers will be required to publish a so-called wage report. This must provide information, in particular, on the gender pay gap across several criteria. Thus, a solid understanding of the definitions in the directive will be key.
Also, it is already advisable that employers begin reviewing their wages and use various techniques to equalize them as soon as possible, so that no differences exceed 5% before the Hungarian rules based on the directive come into force.
This article was first published in the Budapest Business Journal print issue of November 14, 2025.
In other words, very little is known in Hungary about the legislator’s plans beyond the minimum requirements set out in the directive. Even in professional forums, those responsible reveal little about the direction of the regulations.
It seems likely that the legislation will meet the minimum standards or only slightly exceed them. We discuss here some expected legislative trends and mention the practices many companies are already applying and the problems they are facing.
Firstly, it is essential to emphasize that employers must have wage structures in place that ensure equal pay for equal work or work of equal value. The concept of “wage structure” is not defined in the directive. It is unclear whether a clear definition can be expected from the Hungarian legislator in this regard, or whether statistical methodological guidelines will be applicable.
The basic function of pay structures will be to enable an assessment of whether employees are in a comparable position in terms of the value of their work, based on i) skills, ii) effort, iii) responsibility and working conditions, and iv) any other factors relevant to the position in question.
The directive may also impact employers’ recruitment processes. Job applicants must be given the right to receive information about the initial remuneration or remuneration range for the position in question and, where applicable, the relevant provisions of the collective agreement.
Although this is already partially implemented in everyday life, it has been rare for job applicants to be familiar with the rules of collective bargaining agreements before they are hired. Further, it will certainly no longer be possible to ask applicants about their current remuneration.
Employers will have to make the criteria used to determine employee remuneration, wage levels, and wage increases easily accessible to their employees. According to the directive, remuneration includes the regular basic or minimum wage or salary, and any other benefits the employee receives from their employer, directly or indirectly (as a supplementary or variable component), in cash or in kind, in respect of their employment. The wage level is the gross annual remuneration and the corresponding gross hourly wage (the latter indicator is particularly relevant when there is no data available for the entire year for an employee).
Because the concept of a “wage” is not defined in the directive, it is expected that it will be in the local legislation. It is currently unclear whether the Hungarian legislator will define guidelines that will enable employers to easily and uniformly express the value of certain in-kind benefits in monetary terms; at this stage, this appears to be a significant problem for companies preparing for the directive.
Employees shall not be prevented from disclosing their remuneration, and it will be prohibited to apply contractual terms that restrict employees from disclosing information about their remuneration. Thus, we believe that to avoid the application of these rules, it may become practice to terminate the employment of senior managers and employ them under civil law contracts, or even to “relocate” their employment to another company within the same company group.
Employers will be required to publish a so-called wage report. This must provide information, in particular, on the gender pay gap across several criteria. Thus, a solid understanding of the definitions in the directive will be key.
Also, it is already advisable that employers begin reviewing their wages and use various techniques to equalize them as soon as possible, so that no differences exceed 5% before the Hungarian rules based on the directive come into force.
This article was first published in the Budapest Business Journal print issue of November 14, 2025.