Belgium Sounds the Alarm on EU Pay Transparency — But Malta’s Situation May Be Even Worse

Belgium made headlines this week after a study by HR provider SD Worx revealed a troubling trend: nearly eight in ten Belgian SMEs do not understand the new EU Pay Transparency Directive, which all EU member states must implement by June 2026.

The findings caused concern in Brussels, mainly because Belgium is often regarded as an administrative heavyweight with strong policy communication structures. If Belgian businesses are confused, what does that mean for smaller member states?

And this is where Malta enters the picture — because although Malta has already partially implemented the directive, the level of employer awareness is not just unclear; it is almost certainly far worse than Belgium’s.

Belgium Has Data. Malta Doesn’t — and That’s the First Red Flag

The SD Worx study surveyed 523 SMEs and 1,000 Belgian workers. The numbers were stark:

• Only 20% of Belgian SMEs understand the directive.
• 46% have heard of it but don’t know what it requires.
• 32% have never heard of it.

In Malta, no equivalent survey exists. No national study has been carried out by MEAIN, DIER, JobsPlus, MCESD, or any employer organisation.

This means the Maltese government has no data whatsoever about whether Maltese employers understand the law already in force, and everything suggests they do not.

Malta Has Already Passed Part of the Law — But Almost No One Realises It

Unlike Belgium, Malta has already moved ahead with Legal Notice 112 of 2025, which came into force last August.

On paper, this makes Malta a “frontrunner”.

In reality, it means Maltese employers are already legally bound by obligations that many — possibly most — do not even know exist.

The law now requires Maltese employers to:

• Give job applicants salary information before hiring.
• Provide employees, on request, with their own pay data and the average pay for equivalent roles, broken down by gender.
• Justify pay differences using objective and gender-neutral criteria.
• Respond to information requests within two months.

This is a major cultural shift in a country where salary secrecy is still common practice.

Why Malta’s Situation Is Actually Worse Than Belgium’s

1. Belgium discovered a problem. Malta hasn’t even looked.

Belgium now knows the scale of SME confusion.

Malta, with no surveys and no outreach, is effectively blind.

2. Belgium still has time. Malta is already legally bound.

Belgium must transpose the directive by June 2026.

Malta has already enacted part of it — without preparing employers.

3. Belgian workers and SMEs were consulted. Maltese stakeholders were not.

The Belgian policy debate is underway.

In Malta, public communication has been almost nonexistent.

4. Belgium has institutional capacity. Malta depends heavily on micro-enterprises.

Over 90% of Maltese firms are small or micro-enterprises with no HR departments, no internal legal advisers, and no systems for pay audits or gender pay reporting.

If 78% of Belgian SMEs struggle, Malta could easily be at 90–95%, if anyone bothered to measure.

Malta Still Has Major Gaps in the Law

Despite early implementation, Malta still needs additional legislation to comply with the directive fully. Missing parts include:

• A ban on salary history questions (still permitted in Malta).
• Detailed rules for pay gap reporting for medium and large companies.
• Penalties and enforcement mechanisms comparable to EU standards.
• Joint pay assessments are required when a gender pay gap exceeds 5%.

Without these additions, Malta’s law is incomplete — and confusing.

Employers Are Not Ready — And No One Is Telling Them What’s Coming

Maltese businesses, especially micro-enterprises, have not been properly informed of:

• new rights employees now have;
• the shift in the burden of proof in discrimination cases;
• the need for objective pay structures;
• possible future reporting obligations.

As a result, Malta risks a surge in disputes once workers start requesting pay comparisons, which could expose employers who never realised they needed formal pay systems in the first place.

Conclusion: Belgium Is Worrying About the Future. Malta Should Be Worried About the Present.

Belgium’s headlines reveal a country struggling to prepare for a major EU reform. But Malta’s position is more precarious:

• The law is already in force,
• awareness is far lower,
• And no one has measured the impact.

Malta’s early implementation may look admirable on paper, but in practice, it risks creating a silent compliance crisis. Without urgent outreach from government, employer bodies and unions, Malta may discover — too late — that it is far less prepared than Belgium ever was.