Payroll and HR: Pay Transparency and Guidance on Public Holidays

Newsletter – 27.04.2026

Dear clients and partners,

In the current issue of mailingLeitner Slovakia, we focus on two practical payroll and HR topics that currently require employers’ attention. The first is the new legislation on equal pay and pay transparency between men and women, which introduces new obligations for employers in the areas of remuneration structures, recruitment and reporting. The second is the position issued by the Ministry of Labour, Social Affairs and Family of the Slovak Republic regarding the public holidays on 8 May and 15 September 2026, which clarifies their practical treatment from the perspective of working time planning and payroll processing.

In both cases, these are not merely formal topics, but areas with a practical impact on employers – whether in relation to planning work shifts, payroll processing, preparing job offers or setting internal remuneration rules.

Guidance on the public holidays on 8 May and 15 September 2026

The Ministry of Labour, Social Affairs and Family of the Slovak Republic has issued guidance clarifying the practical treatment of the public holidays on 8 May 2026 and 15 September 2026 from the perspective of working time scheduling and payroll processing. Although these days remain public holidays, in 2026 they will not be considered days of rest.

From a practical perspective, this means in particular the following for employers:

these days will be treated as ordinary working days in 2026 for the purposes of working time planning,
employers may assign work to employees on these days in accordance with their employment contracts,
an employee who works on these days is entitled to salary for the time worked and, at the same time, to a wage surcharge / premium for work performed on a public holiday,
if the employer and the employee agree on compensatory time off for work performed on a public holiday, the employee is not entitled to the wage surcharge for work on a public holiday,
if the employee does not work on these days because no work shift was scheduled for that day, the employee is not entitled, on that basis, to a proportional part of salary or to wage compensation,
if the employee takes holiday on these days, the holiday is deducted from the employee’s holiday entitlement in the same way as on any other working day.

From a payroll processing and cost planning perspective, we recommend that employers assess these days in advance with regard to their actual operational needs. If employees work on these days, it is necessary to account for both the regular wage for hours worked and the applicable holiday pay premium. If operations do not require work on these days, it is advisable to consider in advance the use of annual leave or appropriate shift scheduling. These arrangements should subsequently be reflected in working time schedules, attendance records and payroll processing.

Act on Equal Pay for Men and Women

At first glance, it may appear that Slovak legislation already guarantees the right to equal pay without gender-based discrimination in the Labour Code. However, the new Act on Equal Pay for Men and Women for the Same Work or Work of Equal Value, which is expected to enter into force on 7 June 2026, further develops and strengthens this principle, in particular through pay transparency.

While the focus has so far been mainly on salary, the new legislation works with the broader concept of remuneration. This includes not only basic salary, but also other monetary or in-kind benefits provided to employees, which may represent supplementary components of remuneration. In practice, this may include, for example, bonuses, benefits, statutory or non-statutory allowances, or advantages such as the use of a company car for private purposes.

For employers, this means in practice that they will need to comprehensively review and set up so-called remuneration structures. These must be based on objective criteria, including in particular four key areas – the complexity of work, responsibility, effort and working conditions. Each company will need to further develop these criteria according to its own needs, while also taking into account other relevant factors, including so-called soft skills.

These structures must be prepared no later than by 31 July 2026.

The new legislation also introduces reporting obligations regarding differences in remuneration between men and women, applicable to employers with 100 or more employees. Companies with at least 150 employees must submit their first report for the period from August to December 2026 by 7 June 2027. Subsequently, reporting will be carried out annually by employers with 250 or more employees and once every three years by employers with 100 to 249 employees.

If the report shows a difference in the average remuneration of men and women within comparable groups of employees of at least 5%, the employer will be required to objectively justify the difference or adopt measures to eliminate it. Depending on the specific circumstances, a further assessment of the remuneration setup and the adoption of corrective measures may also be required.

A new transparency obligation will also apply in the recruitment process. Employers will be required to provide candidates with information on the amount of remuneration or its range in the job offer, or before the candidate is hired, so that the candidate has transparent information available before negotiations on remuneration. The Act also introduces control mechanisms, sanctions and rules concerning the burden of proof in disputes.

Our experts are actively monitoring this area and will be pleased to assist you with the practical implementation of the new requirements – from training for HR teams, through the review of existing remuneration systems, to the design and setup of transparent remuneration structures.