Ekvio

Employer obligations and the status of the Labour Code amendment

As of 15 September 2026, the Labour Code amendment implementing Directive (EU) 2023/970 is in the Chamber of Deputies as print 300 (distributed 8 September 2026); the first reading is not yet scheduled. It is proposed to take effect on 1 January 2027 (pay system § 109a, applicant information § 30, benefits system § 306a) and 1 January 2028 (employee’s right to information § 306b, report by job groups, pay assessment). The bill and its explanatory memorandum are public; the text may change in the Chamber.

Last checked: 15 September 2026

Timeline

  1. Ministry of Labour presents the draft

    16 March 2026

    A “minimalist” transposition; inter-ministerial consultation 26 Mar – 27 Apr 2026.

  2. Approved by the Government

    31 August 2026

    Approved “with amendments” (ref. 559/26).

  3. Distributed to deputies as print 300/0

    8 September 2026

    Distributed on 8 Sep 2026 with the explanatory memorandum, draft decree outlines and the transposition table. As of 15 Sep 2026 the first reading is not yet scheduled.

  4. First reading in the Chamber of Deputies

    Not yet scheduled. The one risk we track: an amendment to § 109a(2) (three criteria vs. the Directive’s four areas).

  5. Senate

  6. Presidential signature

  7. Publication in the Collection of Laws

  8. First wave takes effect (§ 30, § 109a, § 113, § 306a, § 309b, § 346a)

    1 January 2027

  9. Second wave takes effect (§ 306b, pay report by job groups, assessment)

    1 January 2028

  10. Reporting threshold drops to 100 annual work units

    1 January 2031

The one risk we track: an amendment to § 109a(2) — three statutory criteria versus the Directive’s four areas.

What will be required of you

Three things most companies do not have today

  • A written account of how you set pay

    Today pay grew out of history and negotiation. From January 2027 it must be in an internal regulation: form, components, grading — and job groups ranked by value (complexity, responsibility, demands). For every employer.

    § 109a of the Labour Code · fine up to CZK 1,000,000

  • An answer when an employee asks

    From 1 January 2028 employees may request, in writing and once a year, their own pay and the average in their job group by gender. Two months to reply. Without job groups you have nothing to answer with.

    § 306b of the Labour Code · from 1 January 2028

  • Evidence when someone else asks

    In an equal-pay dispute the burden of proof falls on an employer without a system. A company with a clean result and no documentation is worse off than one with a small gap and a complete trail.

    § 133a(5) of the Civil Procedure Code

Most companies come out clean. The question is not whether you have a gap — it is whether you can prove it.

Obligations and deadlines under the draft

Obligations and deadlines under the draft
ObligationSectionFromApplies toFine up to
Written pay system with job groups ranked by value of workForm, components and grading of pay in an internal regulation or collective agreement; job groups ranked by complexity, responsibility and demands. No transition period — for an employer without a union the internal regulation is the only route.§ 109a of the Labour Code1 January 2027all employersCZK 1,000,000
Pay information for applicants and ban on asking about pay historyDemonstrably inform the applicant of the minimum pay and other benefits before the contract is signed. You may not ask about current or previous pay.§ 30(2) and (3) of the Labour Code1 January 2027all employersCZK 200,000
Pay agreed in writingPay is agreed in writing, with reference to the job group.§ 113(1) of the Labour Code1 January 2027all employers—
System of other monetary benefitsIf you provide benefits or other monetary payments, they need their own system with objective, non-discriminatory criteria — a second document alongside the pay system, again as an internal regulation or collective agreement.§ 306a of the Labour Code1 January 2027all employersCZK 400,000
Ban on restricting employees from discussing payConfidentiality clauses about pay and benefits are not permitted.§ 346a of the Labour Code1 January 2027all employersCZK 400,000
The user’s pay system also applies to agency workersThe user undertaking must provide the agency with the relevant part of its pay system; agency workers count towards the user’s size.§ 309b of the Labour Code1 January 2027users of agency workers—
Employee's right to pay informationOn written request, within 2 months: own pay and the average pay of women and men in the job group for the previous year, in gross annual and hourly terms; the method of calculation is set by decree. Once a year, also via a union or the ombudsman. Inform all employees of this right once a year.§ 306b of the Labour Code1 January 2028all employersCZK 200,000
Pay-gap report by job groupsEmployers with 250+ annual work units every year (first by 30 Apr 2028 for 2027); 150–249 first by 30 Apr 2028, then by 30 Apr 2030 and every three years; 100–149 first by 30 Apr 2031 and every three years. On the prescribed form (annex to the decree, so far only outlined), filed electronically with the Ministry. The § 37g gap report, by contrast, is compiled by the Ministry itself from JMHZ data.§ 37i of the Labour Inspection Act1 January 2028from 150 annual work units (from 2031: 100)CZK 1,000,000
Pay assessment when the gap is 5 % or moreOnly for employers who file the § 37i report. A gap of at least 5 % in average hourly pay between women and men in any job group, unjustified and not remedied within 6 months, triggers a written assessment with employee representatives.§ 287a–287e of the Labour Code1 January 2028from 150 annual work units (from 2031: 100)CZK 1,000,000

Employer size for the report and the assessment is counted in annual work units — the arithmetic mean of monthly work units over 12 months; part-time, agreements and mid-year starts count as fractions. Agency workers count towards the user undertaking (§ 37j).

Who it is for and from when

Obligations by company size

  • up to 49 work units

    From 1 January 2027: pay system (§ 109a), applicant information (§ 30), pay in writing (§ 113), benefits system (§ 306a), ban on pay confidentiality clauses (§ 346a), the pay system for agency workers too (§ 309b).

    From 1 January 2028: reply to an employee's request (§ 306b).

    You do not file a report with the Ministry.

  • 50–149 work units

    The same as smaller companies — from 1 January 2027 and 1 January 2028.

    From 1 January 2031: pay report by job groups every three years (100–149 employees).

    No report until 2031.

  • 150 or more work units

    The same as smaller companies — from 1 January 2027 and 1 January 2028.

    From 1 January 2028: report by job groups (first by 30 April 2028 for 2027; 250+ every year, 150–249 again by 30 April 2030 and every three years thereafter), the 5 % threshold and the pay assessment.

    You file the report with the Ministry via the data box.

Size is counted in annual work units, not headcount: part-time and agreement workers count as fractions, agency workers count towards the user. A company with 130 part-time people may fall below 100.

Accounting firms

You hold the payroll exports of dozens of companies. We are set up for that.

For accountants

What changed

  1. Page created. Status: approved by the Government on 31 Aug 2026, no parliamentary print yet.

  2. The bill is in the Chamber of Deputies as print 300/0 (distributed 8 Sep 2026), with the explanatory memorandum and outlines of the decrees. Added: employer size is counted in annual work units; deadlines for the report by job groups (150–249: 2028, 2030, then every 3 years); § 309b for agency workers; the market value of work is not a criterion of the value of work.

Sources

We check the status on the 1st and 15th of each month on the websites of the Government, the Chamber of Deputies and the Ministry of Labour. When something changes, we record it here with a date.