Portugal pay transparency status
Last reviewed 2026-10-16
Draft only — not law
Portugal has draft text only. Draft text is not law. This page is not promoted.
Portugal (Portugal, PT), capital Lisbon, EU member since 1986. Snapshot: A draft law was published on 5 August 2026.
What applies by employer size
Nothing in these size bands is current national law in Portugal. They restate the Directive floor so a reader can see what transposition would impose. A draft, an internal text, or a government target date is not an employer duty.
Fewer than 100 workers
Article 9 gender pay-gap reporting does not start below 100 workers. Article 5 (pay range or starting pay for applicants, and no pay-history questions) and Article 7 (worker right to pay-level information) are not limited to employers of 100 or more. That is the Directive floor, not a statement that the Member State already imposes it.
100 to 149 workers
Article 9 requires the employer to report the gender pay gap every three years. The Directive sets the first report for 7 June 2031. Joint pay assessment under Article 10 can follow an unjustified gap of at least 5 percent. National law must transpose the duty before it binds a private employer.
150 to 249 workers
Article 9 requires the employer to report the gender pay gap every three years. The Directive sets the first report for 7 June 2027. The same Article 10 joint-assessment rule can apply. National law must transpose the duty before it binds a private employer.
250 or more workers
Article 9 requires the employer to report the gender pay gap every year. The Directive sets the first report for 7 June 2027. The same Article 10 joint-assessment rule can apply. National law must transpose the duty before it binds a private employer.
Deadlines
Transposition deadline for Member States
7 June 2026
Directive (EU) 2023/970. A missed deadline does not by itself create private-employer duties. Source
First Article 9 report, 250 or more workers
7 June 2027, then yearly
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
First Article 9 report, 150 to 249 workers
7 June 2027, then every three years
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
First Article 9 report, 100 to 149 workers
7 June 2031, then every three years
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
Rules on 2026-10-16
Resolved from rule pack version 2026-09-23. Status is enacted, partial, draft, or none. A future effective date is not in force yet.
Pay range for applicants (Article 5)
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 5 requires applicants to receive the initial pay or its range. The Directive does not limit this to employers of 100 or more. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
No pay-history questions (Article 5)
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 5 prohibits asking applicants about their pay history. The Directive does not limit this to employers of 100 or more. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Worker right to pay-level information (Article 7)
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 7 gives workers a right to information on their pay level and average pay levels by sex for the same work. The Directive does not limit this to employers of 100 or more. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — fewer than 100 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 9 does not require gender pay-gap reporting below 100 workers. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 100 to 149 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 100 to 149 workers the Directive sets the first report at 2031-06-07. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 150 to 249 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 150 to 249 workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 250 or more workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 250 or more workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — fewer than 100 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 9 does not require a joint pay assessment below 100 workers. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 100 to 149 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 100 to 149 workers the Directive sets the first report at 2031-06-07. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 150 to 249 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 150 to 249 workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 250 or more workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Portugal: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 250 or more workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law was published on 5 August 2026. A draft or a missing statute is not an employer duty.
Sources
- Directive (EU) 2023/970 on pay transparency (as of 2023-06-06)
- Lockton, EU Pay Transparency Directive — implementation status (table as of 23 September 2026) (as of 2026-09-23)
Directive guides · Gender pay gap calculator
Informational only. This is not legal advice, not a legal opinion, and not a substitute for reading the national statute or instructing counsel. Statutory claims on this page cite Directive (EU) 2023/970 or the Lockton status snapshot and carry a last-reviewed date.