[co-author: Lorraine Matthews]
The adoption of Legal Notice 112 of 2025—Transparent and Predictable Working Conditions (Amendment) Regulations on 27 June 2025 marks Malta’s first legislative step toward implementing the European Union’s pay transparency directive (Directive (EU) 2023/970).
Quick Hits
- The new obligations on pay transparency under Malta’s Legal Notice 112 of 2025—Transparent and Predictable Working Conditions (Amendment) Regulations took effect on 27 August 2025 and apply to both job applicants and existing employees.
- The legislation covers pay range transparency and the right to receive pay information from employers.
- Malta’s Department for Industrial and Employment Relations recently issued a set of FAQs to provide further guidance.
Every employer in Malta, regardless of headcount or sector, is subject to Legal Notice 112. Likewise, it extends to all “applicants for employment,” including part-time and fixed-term workers. The legislation addresses two main areas: pre-employment salary disclosure and providing employees with the right to request and receive information about their own pay and the pay levels for other employees performing the same work.
Job Application Pay Transparency
During recruitment, employers are required to provide the initial pay or pay range and any collective agreement pay provisions relating to the role before the start of employment, differing slightly from the directive, which requires disclosure before interview. This offers employers more flexibility on whether to place salary ranges directly in job advertisements or communicate them via offer letters.
Employee Right to Request Pay Information
Once the employment relationship has begun, employers must respond to employee requests regarding pay levels. Employees can request, in writing, information about their own gross annual and hourly pay as well as the average pay levels for other employees performing the same work. The information on pay includes both annual gross pay and the corresponding hourly rate, as well as a breakdown of any allowances (such as shift allowances, bonuses, or commissions), overtime, and holiday remuneration, where applicable. Unlike the directive, there is currently no requirement in Malta to be informed of pay scales for work of equal value, but as this is a clear requirement within the directive it is expected that this requirement will be implemented in Malta in due course. A response must be provided within a maximum of two months from receipt of the request. If an employer fails to provide the requested information the employee can file a complaint with the Department for Industrial and Employment Relations (DIER) or relevant authority.
Practical Steps
By 7 June 2026, Malta and all EU member states must implement the directive. Employers may want to prepare now for the changes to come through assessing existing pay structures and job architecture to determine whether existing processes and policies align with the minimum requirements of the directive.
Employers may also want to evaluate their current recruitment practices, which could require amendments to disclose pay at an earlier stage in the process. Organisations that are not compliant with the new obligations risk reputational damage and financial penalties.
