The Act uses the Slovak concept of employee (zamestnanec). It applies to employees in employment relationships and similar employment relationships. For the purposes of the Act, judges and prosecutors are also treated as employees, with the relevant court or service office treated as their employer.

The Act does not apply to certain senior public-sector officials, including specified state employees in public office or in statutory body functions and certain employees performing work in the public interest who exercise statutory body functions on the basis of election or appointment. 

The Act does not appear to use the exact term “pay structures” as a defined standalone concept. However, it defines remuneration, pay level, pay differences, and categories of employees, and requires employers to classify employees performing equal work or work of equal value by reference to objective and gender-neutral criteria.

Yes. Employees performing equal work or work of equal value are grouped into categories of employees according to criteria set out in the Act. These criteria include, in particular, skills, effort, responsibility and working conditions, and must be applied objectively and in a gender-neutral manner. Where workers’ representatives operate at the employer, the employer categorises employees after consultation with them.

The employer must provide job applicants with information on the initial pay or initial pay range for the relevant position. Based on the Act’s definition of remuneration, this should be understood by reference to remuneration broadly, including basic pay and other monetary or in-kind benefits provided by the employer, unless further guidance narrows the information to be provided at recruitment stage.

The information must be provided in a manner that enables the applicant to make an informed and transparent decision regarding the employment relationship and before the employment contract is concluded. The Act also amends the employment services framework relating to published job offers. 

The Act prohibits employers from asking job applicants about their remuneration in current or previous employment relationships. The Act does not appear to provide a separate carve-out for internal candidates. Therefore, the safer interpretation is that the prohibition applies to recruitment processes generally, including internal recruitment or promotion processes where the person is treated as an applicant for a position. 

The Act expressly prohibits asking applicants about current or previous remuneration. It does not expressly address whether remuneration information already lawfully known to the employer may be used for internal salary-setting. However, any salary determination must comply with the equal remuneration principle and must be based on objective, gender-neutral criteria. As a risk-based answer, employers should avoid relying on historic pay as a determining factor where doing so could perpetuate unjustified pay differences.

Yes. The employer must ensure that the published job offer and the job title or position title are not based on one sex, that the recruitment process is conducted in a non-discriminatory manner, and that the exercise of the right to equal remuneration is not undermined. 

Employers must make available to employees the criteria used to determine remuneration, pay levels and pay progression. The criteria must be objective and gender-neutral.

The Act requires the information to be made available to employees. The exact format may be determined by employer practice, provided the information is accessible and understandable. Employers should provide it in writing or electronically in a form that can be retained and accessed by employees.

Yes, at a general level. The Act requires the assessment of equal work or work of equal value to be based on objective and gender-neutral criteria, including skills, effort, responsibility and working conditions. More detailed analytical tools and methodologies are to be published by the Ministry of Labour.

Yes. The obligation to make criteria on pay progression available does not apply to employers with fewer than 50 employees, unless otherwise provided by applicable rules or practice

“Pay” or “remuneration” includes basic pay and supplementary components of remuneration.  Basic pay includes, depending on the employment regime, the basic wage component, minimum wage, remuneration under agreements for work performed outside employment, tariff salary, functional salary, rank salary, basic salary of prosecutors or judges, and similar statutory basic remuneration. Supplementary remuneration includes other monetary or in-kind benefits provided by the employer.

The Act defines remuneration broadly and includes other monetary and in-kind benefits provided by the employer. On that basis, voluntary benefits, benefits in kind and other pay components should not be excluded merely because they are not basic salary, unless they do not qualify as remuneration under the Act or further official methodology provides for a specific treatment.

The employer must provide the information within two months of the request.

The information must be provided in writing, including in electronic form, and in a form accessible to the employee.  

No general headcount exemption appears to apply to the individual right to pay information.

Yes. The employee may exercise the right directly. The Act also contemplates access or involvement of workers’ representatives and the Slovak National Centre for Human Rights in certain circumstances, particularly where disclosure of information would identify another employee’s pay.

If the information is inaccurate or incomplete, the employee may request additional clarification or details. If the underlying issue suggests infringement of the right to equal remuneration, the employee may pursue remedies, including monetary compensation, and may rely on the enforcement mechanisms under the Act and anti-discrimination law

Yes. Employers must inform employees annually of their right to request pay information and of the steps by which this right may be exercised.

The Act does not appear to expressly regulate the language of this specific information. However, under Slovak state language rules, employment-related documents and employer communications in Slovakia should generally be provided in Slovak. Therefore, the information should be provided in Slovak. An English version may be provided in addition, for convenience, but should not replace the Slovak version.

Employers cannot prohibit employees from disclosing their own pay.  Such clauses are invalid. However, employers may restrict disclosure of average pay information received through an information request, except where used to enforce equal pay rights.

Existing pay secrecy clauses are invalid. Employers should update templates, policies and contracts and should not enforce such clauses.

The Slovak regime uses the 100, 150 and 250 employee thresholds. 

There are size-specific exemptions, including the exemption for employers with fewer than 50 employees from pay progression transparency. Certain public-sector roles are also excluded.

Unjustified differences must be remedied within the statutory framework and in cooperation with workers’ representatives where applicable. 

The Act requires the employer to eliminate unjustified pay differences. Specific measures may include pay adjustments or changes to pay criteria or categorisation. 

The employer must cooperate with workers’ representatives where they exist and must provide joint pay assessments to the Ministry.  On request, the assessment must also be provided to the labour inspectorate and the Slovak National Centre for Human Rights. 

The Act requires cooperation but does not appear to define “close cooperation” in detail or require agreement in all cases.

A joint pay assessment is required where a pay report shows a gender pay gap of at least 5% in a category of employees, the employer cannot justify it by objective and gender-neutral criteria, and the gap is not remedied within the required period. 

The assessment must analyse the relevant pay differences, affected categories, reasons for the differences and measures to eliminate unjustified gaps. 

The assessment must be made available to employees, workers’ representatives and the Ministry of Labour. It must also be provided to the labour inspectorate and equality body on request.

Where disclosure would reveal the pay of an identifiable employee, access is limited to workers’ representatives, the labour inspectorate and the Slovak National Centre for Human Rights. They must maintain confidentiality and may advise the employee without disclosing the identifiable pay data

If an employer fails to submit required pay reporting information, the Ministry first sets an additional compliance period of at least 15 days.  If the employer still fails to comply, a fine of EUR 4,000 to EUR 8,000 may be imposed.

An affected individual may claim monetary compensation.  This may include unpaid remuneration, compensation for lost opportunities, non-material damage, other harm and default interest. The limitation period is generally three years.

If the employer breaches certain transparency obligations, the burden of proof may shift to the employer.

Workers’ representatives include the trade union body, works council or employee trustee

If there are no workers’ representatives, the employer must still comply with employee-facing and authority-facing obligations. Representative-specific consultation obligations apply only where representatives exist.

Representatives have consultation and information rights in relation to employee categorisation, joint pay assessments and certain pay information. 

Failure to engage representatives where required may constitute a breach and may affect the employer’s ability to demonstrate compliance. 

Representatives are involved in categorisation and joint pay assessments. The Ministry will publish analytical tools and methodologies.

The main claim belongs to affected employees. Representatives support the process through consultation, information access and involvement in assessments

No other notable matters have been identified at this stage. No additional secondary legislation or guidance has been published yet. The Ministry of Labour is expected to publish analytical tools and methodologies to support the assessment and comparison of work value