Pay transparency in Finland
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Pay information requests 1 Jan 2027 (proposed)
Own pay and sex-disaggregated averages for the same/equal-value worker group. If those averages would directly or indirectly identify another worker's pay, the proposed §6g routes the group information to a personnel representative or the Equality Ombudsman rather than directly to the requester; no fixed statutory minimum group size is specified.
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Time to respond 2 months
Every request starts a clock. Answering one needs pay structures and equal-value groupings that already exist.
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Salary history questions are banned
Applicants learn the pay range before the interview, and employers may not ask what they earn today.
Finland is preparing its pay transparency rules through Government Proposal HE 129/2026 vp, which would amend the Act on Equality between Women and Men and related acts. This is a published draft, not a law in force. It has been submitted to Parliament but has not yet been enacted.
The proposal would apply nationwide across public and private employment. It sets a proposed commencement date of 1 January 2027 for the core obligations, and it would sit alongside Finland’s existing framework requiring employers with regularly at least 30 employees to keep an equality plan that includes a pay survey. That existing regime continues regardless of how the new proposal progresses.
Finland’s draft goes further than the EU baseline in some respects, including a lower reporting threshold and a defined trigger for closer pay analysis. For now, the right move is to track how Parliament treats HE 129/2026 and start preparing your data and processes ahead of the proposed 2027 start.
The measure
- Law or measure
- Government Proposal HE 129/2026 vp, amendments to the Act on Equality between Women and Men and related Acts
- Core obligations start
- 1 Jan 2027 (proposed)
- Who is covered
- Proposed rules apply across public and private employment. The reporting model covers Finnish entities and foreign entities with a Finnish permanent establishment, from 100 employees; HE 129/2026 remains draft.
What the law requires
- Pay range before the interview Source for: Pay range before the interview
- Salary history questions banned Source for: Salary history questions banned
- Pay information requests, 2 months to respond Source for: Pay information requests, 2 months to respond
- Gap reporting from 100 employees Source for: Gap reporting from 100 employees
- Joint pay assessment at a 5.0% gap Source for: Joint pay assessment at a 5.0% gap
How Finland differs from the Directive
Finland already requires employers with regularly at least 30 employees to maintain an equality plan including a pay survey. HE 129/2026 proposes a centralised reporting model using the Incomes Register and Statistics Finland, and proposes first 150+ reporting only in 2028 for 2027 data, later than the Directive baseline.
On at least one point the national rules go beyond the Directive minimum, so preparing to the EU baseline alone is not enough here.
What this means for employers
Under the proposal, employees would gain the right to ask for their own pay level and sex-disaggregated average pay for workers doing the same work or work of equal value. Employers would have a proposed two month window to respond. A gender pay gap of 5.0% or more would trigger a joint pay assessment, and the draft also includes a salary range rule and a ban on asking candidates about salary history.
Reporting duties would apply to employers with 100 or more employees, using a proposed hybrid model where Statistics Finland and the Incomes Register handle six of the EU’s seven pay-gap indicators centrally, while employers stay responsible for the equal-work and equal-value category indicator. Larger employers would file first, with filing due by 2 May 2028 and transmission to Statistics Finland by 7 June 2028 for 2027 data. Employers with 100 to 149 employees would follow later, with filing due by 2 May 2031 and transmission by 7 June 2031 for 2030 data. These dates are set out in the proposal itself but remain subject to parliamentary amendment.
None of this replaces your existing obligations if you already have 30 or more employees. Your current equality plan and pay survey process continues either way.
- Watch Parliament’s progress on HE 129/2026 vp so you know if and when the proposed dates firm up.
- Build recruitment controls for pay ranges and remove any salary history questions from your hiring process.
- Document your pay and progression criteria so they are objective and gender-neutral, ready to support any pay information request.
- Set up a pay-information workflow that can respond to employee requests within the proposed two month deadline.
- If you have 100 or more employees, check your Incomes Register and payroll data quality now, and start mapping equal-value job categories.
- Keep your existing 30+ equality plan and pay survey process running alongside any new preparation work.
Enforcement and open questions
- Competent authority
- Ministry of Social Affairs and Health (legislative lead); Ombudsman for Equality / National Non-Discrimination and Equality Tribunal for supervision and enforcement under the Equality Act framework.
- Equality body
- Ombudsman for Equality (Tasa-arvovaltuutettu).
- Penalties
- Proposed §21b: failure to submit the joint pay assessment can attract a €5,000-€80,000 neglect fee, with proportionality and minor-breach relief and specified public-body exemptions. The Tribunal can order compliance with the listed transparency duties, backed by a conditional fine.
- What could still change
- The Incomes Register guide issued 2 November 2026 states that the pay-transparency reporting rules apply from 1 January 2027 and gives detailed filing mechanics, but HE 129/2026 was still before Parliament when freshly checked on 4 November: PJ 106/2026 scheduled the first reading, and no completed reading, final vote, enactment or promulgation was verified. The guide is competent-authority operational evidence, not proof of enactment. Final statutory text may change.
Common questions
Is Finland's pay transparency law already in force?
No. HE 129/2026 vp is a published government proposal submitted to Parliament, not enacted law. The proposed commencement date for the core obligations is 1 January 2027, but this is not yet confirmed.
When would employees in Finland be able to request pay information?
Under the proposal, employees would have the right to request their own pay level and sex-disaggregated average pay for a worker group doing the same work or work of equal value. Employers would have a proposed two month deadline to respond. This right is not yet in force.
Which employers in Finland would need to report gender pay gaps?
The proposal sets a reporting threshold of 100 employees or more. Larger employers would file first, with employer filing due by 2 May 2028 and transmission to Statistics Finland by 7 June 2028 for 2027 data. Employers with 100 to 149 employees would follow with filing due by 2 May 2031 and transmission by 7 June 2031 for 2030 data.
Does Finland already have pay reporting rules today?
Yes, separately from the new proposal. Employers with regularly at least 30 employees already must maintain an equality plan that includes a pay survey, and this existing framework continues alongside HE 129/2026 vp.
How does Finland's proposed reporting model work?
The proposal uses a hybrid, centralised model. Statistics Finland and the Incomes Register would handle six of the EU's seven pay-gap indicators centrally, while employers would remain responsible for reporting the equal-work and equal-value category indicator themselves.
Who enforces pay transparency rules in Finland?
The Ministry of Social Affairs and Health leads on the legislation, while the Ombudsman for Equality and the National Non-Discrimination and Equality Tribunal handle supervision and enforcement under the existing Equality Act framework.
- Pay information request right Art. 7(1)
- 1 Jan 2027 (proposed)
- Response deadline Art. 7(4)
- 2 months
- Salary range in recruitment Art. 5(1)
- Yes
- Salary history questions banned Art. 5(2)
- Yes
- Joint pay assessment trigger Art. 10(1)
- 5.0%
Own pay and sex-disaggregated averages for the same/equal-value worker group. If those averages would directly or indirectly identify another worker's pay, the proposed §6g routes the group information to a personnel representative or the Equality Ombudsman rather than directly to the requester; no fixed statutory minimum group size is specified.
Government proposal establishes the proposed employee pay-information right; not enacted.
Read the sourceThe employer must answer in writing within this period.
Proposed two-month response period; not enacted.
Read the sourceApplicants receive the pay or pay range before the interview, based on objective, gender-neutral criteria.
Government proposal supports a salary/pay-range information requirement in recruitment; not enacted.
Read the sourceWhether employers are prohibited from asking applicants about their current or previous pay.
Government proposal supports the proposed restriction on requesting prior pay information; not enacted.
Read the sourceThe unjustified gap that obliges the employer and worker representatives to assess pay together.
The proposal uses a 5% category-level gap threshold subject to the additional statutory conditions; not enacted.
Read the source- Reporting threshold
- 100 employees
- Reporting model
- Proposed hybrid / centralised Operational data-production and filing model for pay-gap reporting: employer-calculated, authority-calculated, hybrid, proposed, pre-existing or absent.
- First report, 250 or more employees
- Employer filing by 2 May 2028 (2027 data); Statistics Finland transmission by 7 Jun 2028
- First report, 100 to 149 employees
- Employer filing by 2 May 2031 (2030 data); Statistics Finland transmission by 7 Jun 2031
- Metrics required
- EU seven; proposal uses a centralised national-data model for six indicators, while the employer remains responsible for the equal-work/equal-value category indicator. Art. 9(1): Seven metrics: mean gap; variable-component gap; median gap; median variable gap; variable-pay participation by sex; quartile distribution by sex; category-level gap split basic and variable.
- Pre-existing regime
- Existing 30+ equality-plan and pay-survey framework continues alongside the proposal.
- Formal transposition stage
- Published draft
- Scope
- Nationwide
Next milestone
Verify the completed outcome of the 4 November first reading, then second reading, any amendments and votes, enactment/promulgation and final commencement. Reconcile the 2 November Incomes Register guide if Parliament changes HE 129/2026.
Primary sources
- Government Proposal HE 129/2026 vp — amendments to the Act on Equality between Women and Men and related Acts Primary source, checked 4 November 2026
- Formal transposition stage Published draft · proposed · High confidence
- Core employer obligations Not operational · proposed · High confidence
- Transposition scope Nationwide · proposed · High confidence
- Salary range in recruitment Yes · proposed · High confidence
- Salary history questions banned Yes · proposed · High confidence
- Pay information request right Yes · proposed · High confidence
- Response deadline 2 months · proposed · High confidence
- Reporting threshold 100 · proposed · High confidence
- First report, 250 or more employees Employer filing by 2 May 2028 (2027 data); Statistics Finland transmission by 7 Jun 2028 · proposed · High confidence
- First report, 100 to 149 employees Employer filing by 2 May 2031 (2030 data); Statistics Finland transmission by 7 Jun 2031 · proposed · High confidence
- Reporting model Proposed hybrid / centralised · proposed · High confidence
- Joint pay assessment trigger 5% · proposed · High confidence
- Info reference period Unclear · unclear · High confidence
- Info pay basis Unclear · unclear · High confidence
- Info pay components scope Unclear · unclear · High confidence
- Info request frequency Unclear · unclear · High confidence
- Info employee reference period eligibility No specific prior-period eligibility condition was resolved from the official government proposal in this review. · proposed · High confidence
- Info normalisation method Unclear · unclear · High confidence
- Reporting reference period Previous calendar year · proposed · High confidence
- Reporting pay basis Actual remuneration paid / earned · proposed · High confidence
- Reporting pay components scope Different / modified · proposed · High confidence
- Reporting population basis Reporting covers Finnish entities and foreign entities with a Finnish permanent establishment. The 100-worker threshold is assessed company-by-company over the calendar year and treated as met when exceeded for at least nine months. Include own employees wherever they work, including posted abroad; exclude locally hired workers of a Finnish company’s foreign permanent establishment paid under local rules, user-company agency workers, and optional exceptional temporary/short seasonal workers; do not aggregate group companies; exclude fee/work-compensation recipients. For worker-group gap calculations, employees on full-period unpaid leave are excluded, while partial-period leave remains included. · proposed · High confidence
- Reporting normalisation method Actual paid wages; category gaps are calculated separately from hourly and annual earnings, using women’s average / men’s average × 100 rounded to the nearest integer. Only authority-listed income types enter the calculations; single-sex groups are flagged without a gap, while a gap is reported where one sex has one employee. Pay follows the work group/work period, while longer-accruing bonus and holiday-pay items follow the payment-date group under the authority’s current view. Full-period unpaid leave is omitted from group gaps; partial-period leave remains included. Undue benefits follow the original income type without reducing pay; recoveries reduce the matching component. · proposed · High confidence
- Employer required input data Itemised 200-series cash-pay income types, employment type (full-/part-time), agreed regular weekly hours, part-time percentage, and objective same/equal-value worker-group assignment are required, with group-level base, supplementary and variable results in hourly and annual form. The data remain technically optional in the general Incomes Register schema but are effectively mandatory for covered employers; required data unavailable from payroll must be added manually, while hours/percentage may be omitted only where they were not agreed or are genuinely unavailable. Split payroll reports when service data change mid-pay-period. Normally one group applies, but wholly separate jobs may be split and pay allocated. Palkka.fi cannot submit these fields. · proposed · High confidence
- First data period needed 2027 data for the first 2028 filing for employers with at least 150 workers; 2030 data for the first 2031 filing for 100-149 workers. · proposed · High confidence
- Own pay information Yes · proposed · High confidence
- Comparator information Yes · proposed · High confidence
- Comparator information start 1 Jan 2027 (proposed) · proposed · High confidence
- Annual average information start · proposed · High confidence
- Equal value criteria Under HE 129/2026 proposed §3a, the employer would use a collective-agreement-based or other method to identify equal-value work. TyVM 9/2026 states that competence, effort/load, responsibility and working conditions are examples/upper concepts rather than mandatory labels; weights may vary and a factor may carry zero weight for a particular job, but every factor used must be relevant, objective and gender-neutral. If a collective-agreement method does not adequately reflect job demands, another method is required. The STM voluntary six-factor model remains one possible tool. The proposal is not enacted. · proposed · High confidence
Change history
Recent updates
Finland issues consolidated Incomes Register pay-transparency reporting guide
Finland’s Incomes Register issued a consolidated reporting instruction on 2 November 2026.
Finland’s committee backs HE 129/2026 and clarifies equal-value assessment
Finland’s Work Life and Equality Committee recommends adopting the core HE 129/2026 bills unchanged and clarifies the proposed method for identifying work of equal value.
Finland clarifies proposed pay-transparency reporting mechanics
Finland’s Incomes Register has published official webinar materials clarifying which employers and workers are covered and how worker groups, absences and required payroll fields would be handled...
Finland’s equality authority calls for changes to the pay-transparency bill
The Equality Ombudsman has raised implementation concerns in its parliamentary opinion on HE 129/2026. These recommendations have not amended the bill.
Finland expands Incomes Register pay-transparency reporting guidance
Finland’s Incomes Register has expanded its proposal-dependent pay-transparency guidance with an official income-type mapping and detailed rules for worker groups, sensitive small groups, pay...
This page is maintained by Evenpay from official primary sources and reviewed before publication. It is general information, not legal advice. Requirements vary by member state and change as national laws progress; figures described as proposed are subject to amendment.
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