Pay Transparency. Slovak Rules and Preparing HR Data

Slovak employers now have enacted domestic rules to work from. Act No. 76/2026 took effect on 7 June 2026. Section 18 required employers established before that date to introduce pay structures by 31 July 2026.

The Slovak transitional provisions also define the first reporting period. Employers with at least 150 employees submit by 7 June 2027 for 1 August to 31 December 2026. Those with 100 to 149 employees first submit by 7 June 2031 for 2030. The year on the reporting deadline alone is not enough to define an export.

Separate the Directive from domestic implementation

Directive (EU) 2023/970 set Member States a transposition deadline of 7 June 2026. The overview below describes its framework. Assess actual duties, procedures and transitional rules under the applicable domestic law.

The Directive also covers information for applicants. An employer must communicate the initial pay or a pay range in the vacancy notice or before the interview, so pay can be negotiated on an informed basis. It also restricts questions about pay history. Domestic rules may determine the practical form, so check it before you copy the process that another country already runs.

Article 9 sets the reporting timetable. Employers with 250 or more workers first report by 7 June 2027 and then annually. At 150 to 249 workers the first date is the same, with further reports every three years. Anyone with 100 to 149 workers starts by 7 June 2031 and then reports every three years. National law may also address smaller employers.

Article 7 gives workers the right to request written information about their own pay and average pay by sex in a comparable work category, which the employer has to be able to define. The Directive sets a response deadline of two months. Record the request and the deadline. Note who is entitled to receive the answer. Check the protection of identifiable colleagues in small groups.

Preparation does not have to begin with a new HR system. First map the sources of base pay, bonuses, and benefits, then the comparable work categories, and finally the data owners who sign off on every change. Comparison criteria should be objective and gender-neutral. A useful export includes a worker identifier, work category, period, and pay components, each with its source, so anyone can trace where the numbers in the report came from. Process sex data only where you have a lawful basis.

A system may need access roles, change history, dated snapshots, and checks for whatever is missing from the data. This is not a mandatory feature list or legal advice. It is a way to prepare a repeatable export with traceable data. Confirm minimisation and retention for personal data. Access controls get their own pass.

Do not judge AI in HR as one block. What matters is the intended purpose and the effect on people, and the same model can land on either side of that line depending on where you plug it in. Both CV sorting and interview selection need assessment in their intended use. Read our article on AI in employment and see our technology audit service for technical preparation.