ELA EU Pay Directive

CYPRUS

Legislation Addressing the EU Pay Directive

  • How will the Directive's requirements interact with or replace existing national obligations?

    By majority, the draft transposing legislation largely reflects the Directive with some minor deviations. Accordingly, there are several aspects in which the Cypriot draft law appears to introduce requirements that go beyond the minimum harmonisation standard of Directive (EU) 2023/970:

    a. The 20% cap on pay ranges

    Article 6(1)(α) of the Cypriot draft law provides that where the information given to job applicants concerns a pay range rather than a fixed initial salary, the difference between the upper and lower limits of that range must not exceed 20%. The Directive requires disclosure of a pay range but does not prescribe a maximum spread between the upper and lower limits. This cap is a Cypriot addition and imposes a stricter constraint on how employers may structure pre-employment pay disclosures.

    b. Criminal sanctions and personal liability.

    Article 27(1) of the Cypriot draft law provides that an employer who contravenes any provision of the law is guilty of a criminal offence and, upon conviction, is liable to imprisonment not exceeding six months, a fine not exceeding €10,000, or both. The Directive requires effective, proportionate, and dissuasive penalties but does not mandate criminal liability. The imposition of custodial sanctions is a domestic choice that exceeds the Directive's minimum enforcement requirements. Moreover, the aforementioned sanctions may be extended to individuals holding a managerial, chairman/president, director, secretary or other similar position within a company or appears to be acting in such capacity, unless they are able to prove that the offence was committed without their consent, complicity or negligence

    c. Documentability requirement for pre-employment disclosures

    Article 6(1) further provides that the manner in which pay information is disclosed before interview must be such that it can be evidenced by the employer when required. The Directive does not expressly impose this documentary accountability obligation on employers at the pre-employment stage, making this an additional procedural requirement under Cypriot draft law.

    d. Weighted job-evaluation criteria.

    The objective, gender-neutral job criteria applied for assessing whether workers are in a comparable situation in regard to the value of work must additionally be 'weighted' according to its relevance to a specific job or position. The Directive lists skills, effort, responsibility, and working conditions as the criteria for assessing "equal value," and only discusses weighting in its recitals (non-binding preamble). Cyprus's operative text makes weighting of those criteria an explicit legal requirement, which points toward a more prescriptive, documented job-evaluation methodology than the Directive strictly mandates. 

    e. Retrospective data requests.

    Upon request by the Inspector and/or the Ombudsman, employers must provide gender pay gap data for up to four previous years. This may require retrieving data from as far back as 2022. By comparison, the Directive does not set any retrospective scope for historical pay-gap data


  • When will transposing legislation be published and what to expect:

    As of 25 June 2026, Cyprus has not yet enacted the transposing legislation, (having missed the EU transposition deadline of 7 June 2026). However, a draft law is at an advanced stage of preparation which represents a near-complete legislative text. The public consultation period on the draft law concluded on 4 December 2025. No official date of enactment has been confirmed at the time of writing, though the bill's own provisions indicate an intention to publish it in the Official Gazette imminently, given that Article 36 provides that the law enters into force on the date of its publication in the Official Gazette of the Republic. Nonetheless, transposition is not expected to take place until at least Q4 2026.


    Once enacted, the legislation will cover the following principal areas:

    - Pay structures and equal value: requiring employers to maintain gender-neutral pay structures based on objective criteria including skills, effort, responsibility, and working conditions. 

    - Pre-employment pay transparency: requiring disclosure of initial pay or pay range (capped at a 20% spread) before interview, and prohibiting salary history enquiries;

    - Transparency of pay setting and pay progression allowing access to employees regarding the criteria used to determine pay, pay levels and pay progression, with the exception of employers with less than 50 employees from the obligation relating to pay progression;

    - Employees pay transparency rights: requiring employers to proactively publish pay criteria and respond to individual pay information requests within two months;

    - Pay gap reporting: a tiered mandatory reporting regime based on headcount thresholds of 100, 150, and 250 employees;

    - Joint pay assessments: triggered when a gender pay gap of at least 5% in any employee category is identified and not corrected within six months;

    - Technical support and training by the relevant authority to employers with less than 250 employees for better facilitate compliance with the requirements of the law;

    - Rules and restrictions related to personal data protection;

    - Enforcement: through Labour Inspectors the Commissioner for Administration (Cypriot Ombudsman), and the Cypriot Labour Court, with possible criminal sanctions of up to six months imprisonment and/or a fine of up to EUR 10,000, which may be extended to individuals holding a managerial, chairman/president, director, secretary or other similar position within a company or who appears to be acting in such capacity, unless they are able to prove that the offence was committed without their consent, complicity or negligence; 

    - Reversed burden of proof: applying in all civil and administrative proceedings, and automatically where pay transparency obligations have not been met;

    - Non victimization and non-retaliation (including protection from termination) against employees who seek to enforce their rights provided by the law. 


Application

Recruitment and job applicants

Transparency of pay and pay progression policy

Individual rights to pay information

Prohibitions on workers disclosing pay information

Gender pay gap reporting

  • Are the pay gap reporting deadlines the same as those set out in the Directive?

    INSERT ANSWER

  • Does local law specify how employers should consider employees that choose not to identify with a particular gender?

    INSERT ANSWER

Dealing with Gaps & Joint Pay Assessments

Data Protection

Breach of pay transparency and pay gap reporting requirements

Rights to equal pay – rights of action

Workers Representatives

Member State Support

Other/Additional