The deadline for national transposition of Directive (EU) 2023/970, the EU Pay Transparency Directive, is 7 June 2026. The rules it introduces on salary disclosure, pay gap reporting, and hiring practices apply to all employers with staff in EU member states — including iGaming operators and suppliers headquartered outside the bloc.
The directive entered force in May 2023. Three years later, with implementation required across all 27 member states, most major EU iGaming markets are still finalising national legislation. The European Commission has confirmed it will pursue infringement proceedings against member states that miss the deadline.
What the Directive Requires
The directive’s obligations fall into three areas: recruitment transparency, ongoing employee rights to pay information, and gender pay gap reporting for larger employers.
From June 2026, all employers — regardless of headcount — must make accessible to employees the criteria used to determine pay, pay levels, and the rules governing progression. Pay secrecy clauses are prohibited. Employees cannot be contractually prevented from discussing their salaries with colleagues. Any employee can request in writing their own gross annual and hourly pay, alongside average pay levels for colleagues performing equivalent work. Employers must respond within two months.
The average gender pay gap across the EU stands at 13%, according to Eurostat. The directive is designed to reduce that figure by making pay structures visible, enforceable, and open to challenge.
What Changes in Hiring
The most immediate operational change affects recruitment. Salary ranges must be disclosed to candidates before the interview stage — either in the job posting or prior to first contact. The range must reflect what the employer will realistically pay, based on documented criteria. Ranges set so wide as to provide no meaningful guidance do not satisfy the directive’s intent, and hiring teams will need documented criteria to justify where within a band a candidate sits.
Employers are prohibited from asking candidates about their current or previous salary. That ban removes a mechanism that historically anchored new offers to prior pay — often suppressing salaries for candidates moving from lower-wage markets or employers. For iGaming talent relocating across EU member states, or from outside the bloc into major licensing hubs, the change removes a structural disadvantage at the start of salary negotiations.
All job titles and vacancy notices must be gender-neutral.
Reporting Obligations and the 5% Threshold
Reporting requirements are phased by company size. Employers with 250 or more employees must report gender pay gap data annually, starting in June 2027 based on 2026 data. Those with 150 to 249 employees report every three years from 2027. Companies with 100 to 149 employees begin triannual reporting in 2031. Businesses with fewer than 100 employees are exempt from mandatory reporting, though individual member states may lower that threshold during national transposition.
Reports must cover pay gaps in base pay, bonuses, and any additional compensation, broken down by category of worker. Where a gap of 5% or more exists within a worker category and cannot be justified on objective grounds, the employer must undertake a joint pay assessment with employee representatives. If the gap is not resolved within six months of that finding, enforcement follows.
The burden of proof shifts to the employer in cases of suspected pay discrimination. Where an employer has not met its transparency or reporting obligations, discrimination is presumed unless disproved.
What This Means for iGaming
The iGaming industry competes for technical talent — developers, data engineers, compliance officers, trading specialists, and live casino operations staff — against fintech, financial services, and wider technology companies across EU labour markets. Salary range disclosure in job postings is less disruptive for operators with structured, documented pay bands than for studios or suppliers that have historically set compensation through ad hoc negotiation. Companies without formalised pay criteria will face the greatest pressure to restructure how they justify and communicate compensation decisions.
The sector skews male in technical and leadership roles, consistent with the broader technology industry. For large operators, mandatory reporting will make structural pay gaps visible in a way that was previously voluntary in most EU jurisdictions. Several UK-licensed operators already produce gender pay gap reports under existing domestic requirements. For those groups, EU compliance is an extension of existing practice. For suppliers without that reporting infrastructure, building the payroll data capability to isolate gaps by worker category requires time and systems investment.
The prohibition on salary history questions removes a negotiation anchor that has disadvantaged candidates moving from smaller operators or lower-average-wage markets. The change also has direct relevance to iGaming companies that recruit internationally — a routine practice in Malta, Gibraltar, and other licensing centres drawing from diverse EU talent pools.
The directive’s scope extends to non-EU companies with EU-based employees. iGaming businesses headquartered in Gibraltar, the Isle of Man, or elsewhere outside the EU but employing staff across member states fall within scope.
Malta’s Position
Malta, home to a significant portion of the EU’s licensed iGaming operations, moved ahead of the June 2026 deadline in limited form. Legal Notice 112 of 2025, effective August 2025, introduced pay disclosure obligations at the point of recruitment and employee rights to request pay information from employers. Full transposition — covering gender pay gap reporting requirements, pay secrecy bans, and enforcement penalties — is expected by the June 2026 deadline, though precise penalty frameworks had not been confirmed at the time of writing.
For MGA-licensed operators, the directive adds an employment compliance layer to manage alongside existing AML, KYC, and responsible gambling obligations. The coordination between EU member states on cross-border oversight has expanded steadily, seven European gambling regulators convening in Madrid last year addressed exactly those mechanisms.
What Operators and Suppliers Need to Do
The compliance steps are clear. Audit existing pay structures and document the criteria used to determine compensation across roles. Identify unexplained pay gaps before a mandatory report forces the finding. Build or formalise salary bands with objective criteria. Remove pay secrecy clauses from employment contracts. Update job postings and interview processes to include salary ranges and remove pay history questions. Train hiring managers and HR teams on the new obligations.
For companies with UK-licensed operations already absorbing pressure from the confirmed gambling duty increases taking online casino to 40% and sports betting to 25%, the directive represents an additional compliance workstream landing in the same period.
For companies with 250 or more employees, the first mandatory gender pay gap report is due June 2027, based on 2026 compensation data being generated now. Operators that begin calculating their pay gaps for the first time under enforcement pressure, rather than ahead of it, risk immediate public exposure of gaps they have had no time to remedy.
Source: European Commission / Directive (EU) 2023/970
