Malta Implements Pay Transparency Obligations: What Employers Need to Know

With effect from 27th August 2025, employers in Malta are now required to comply with new obligations on pay transparency, marking a significant shift in local employment law. These changes were introduced through Legal Notice 112 of 2025, published on 27th June 2025, which amended the Transparent and Predictable Working Conditions Regulations (S.L. 452.126)

This new legal framework is Malta’s first step towards implementing the EU Pay Transparency Directive (Directive (EU) 2023/970), which must be fully transposed into Maltese law by 7th June 2026. Employers should therefore see these changes not as isolated rules, but as the beginning of a wider transformation in how pay and conditions are managed across the EU.

Pay Transparency for Job Applicants

The new legal notice requires employers in Malta to provide job candidates with clear and practical pay information before employment begins. This is intended to create greater fairness and transparency at the recruitment stage. In particular, employers must now:

• Indicate salary levels: Employers must disclose either the exact starting salary or the broader pay range linked to the position. This allows candidates to understand both their entry point and the potential progression available within their role.
• Share relevant collective agreement terms: Where a role is covered by collective agreement, employers are obliged to provide the applicant with the sections of the agreement that relate to pay.

The FAQs issued by the Department for Industrial and Employment Relations (DIER) explains that “pay” goes beyond basic salary. It includes overtime, allowances such as shift or performance pay, vacation and public holiday entitlements, and statutory bonuses payable under Maltese law.

These change mean that employers can no longer rely on vague references such as a “competitive salary”. Instead, candidates must be given clear and structured pay information, enabling them to make an ensure decision when considering a role.

Pay Transparency for Existing Employees

The legal notice also introduces new rights for existing employees. Workers can now submit a written request at any time to receive:

• Their individual pay level (defined as gross annual pay and gross hourly pay).
• The average pay levels of workers performing the same work.

Employers are obliged to provide this information within two months of receiving the request.

Importantly, the DIER has clarified that “pay level” refers to the salary band or range associated with the role, rather than simply a single numerical figure.

What’s Next Under the EU Directive?

Legal Notice 112 of 2025 is only a partial transposition of the EU Pay Transparency Directive. By June 2026, employers can expect additional obligations, including:

• A ban on asking about candidates’ salary history.
• The right for employees to compare pay for work of equal value, not just the same role.
• Gender pay gap reporting for companies employing more than one hundred employees.
• The prohibition of pay secrecy clauses, allowing employees to openly discuss their remuneration.
• Stronger enforcement mechanisms and penalties for non-compliance.

These upcoming measures will require employers to adopt more structured, transparent, and documented pay practices.

Final Thoughts

Legal Notice 112 of 2025 represents more than a technical adjustment to Malta’s employment laws; it marks the beginning of a broader shift towards transparency and accountability in pay practices. While the current obligations focus on disclosure during recruitment and employee access to pay information, the forthcoming transposition of the EU Pay Transparency Directive will extend these requirements considerably, with pay gap reporting, equal value comparisons, and stronger enforcement mechanisms on the horizon.

We strongly believe that employers should approach these developments strategically. Early action, such as reviewing recruitment materials, formalising pay structures, and preparing for reporting duties, will not only ensure compliance but also strengthen employee confidence and enhance competitiveness in the labour market.

At GB Legal, we have a dedicated team monitoring these changes and assisting employers in adapting to them. We see this as an opportunity for organisations to align their practices with emerging European standards, positioning themselves ahead of the curve rather than reacting under pressure.