If you have looked for a job in Portugal, you know the routine: an advert without a single figure, and a screening call where you are asked what you earn at the moment. And only right at the end, a number that often turns out to be well below the one that would have made the whole process worth going through.
From 2026, or so it was assumed, that would no longer be allowed. The EU adopted the pay transparency directive (2023/970), and every member state was supposed to transpose it into national law by 7 June. One of its provisions was widely read to mean that pay would have to be stated in the vacancy itself.
Portugal missed the deadline. And on 5 August the government finally published its draft law — with no obligation to publish pay in the advert.
That does not mean nothing changes. Things do change, and some of the changes bear directly on people who have relocated.
Portugal already had a framework of equal pay rules: article 24 of the Labour Code (the general ban on discrimination), Lei 60/2018 with its mechanisms for promoting equality in pay, and annual government reports on the pay gap, which the state compiled itself from the data it already holds.
What was missing from it, and what appears now:
- a ban on asking a candidate about their current and past pay;
- the right of an employee to obtain data on what colleagues in comparable positions are paid;
- an obligation on companies to explain the criteria by which they set pay at all;
- a ban on contract clauses requiring people to keep their salary secret.
What Changes, Point by Point
The question about past pay is off limits. An employer will no longer be able to ask what you earn now or earned before. This provision is transposed in full, with no softening, and it is the most solid part of the draft.
Why this matters particularly to people who have moved: until now your previous salary worked as an anchor. You named a figure from Tbilisi, Warsaw, São Paulo or Bucharest, and the negotiation then ran from that figure rather than from the Portuguese market — with a polite top-up “for the relocation”. The employer got a strong position for free, simply by asking one question at the start of the screening. Now the bargaining formally starts from a blank sheet.
You will be given the number — but not necessarily early. A candidate gains the right to information about the starting salary or the range before signing an employment contract. The directive put it differently: the information should arrive early enough for the negotiation to be an informed one, and it allowed three routes — in the advert, before the interview, or by some other means. The Portuguese draft kept only the last of them, and the latest possible moment. So the figure does have to be given to you, but it can come once you have already been through the entire selection process and invested in it psychologically.
Silence about pay is over. Contract clauses barring you from discussing your pay with colleagues are void. In practice that means comparing notes across a team stops being a breach of contract.
A right to data appears. An employee will be able to make a formal request to their employer for their own pay level and for the average levels, broken down by sex, among people doing work of equal value. The company will have two months to reply. Until now the only way to find this out was to ask a colleague and hope they answered honestly.
Criteria will have to be disclosed. Companies of 50 people or more must make available the rules by which pay, pay levels and career progression are determined. Those criteria must be objective and the same for men and women.
Reporting moves onto the companies. The gap used to be calculated by the state. Now employers will report it themselves: companies of 250 employees and up annually, those with 150 to 249 every three years, and those with 50 to 149 with a first report expected in 2031.
These are substantial tasks. According to the Guia Hays 2026, fewer than 30% of Portuguese vacancies currently carry any mention at all of the pay on offer.
Who Gains From This?
Anyone who arrived with a salary from another country. The main gain, and almost nobody writes about it. Dropping the question about past pay strikes at the very mechanism that was pushing down offers made to people who had just moved.
Anyone who knows how to negotiate. The absence of a range in the advert works in favour of people with international experience and a clear market value. A published range is also a ceiling. When there is no figure, a strong candidate keeps room to move.
Anyone already working at a company of 50 or more. You get a working instrument instead of rumours: a written request with a mandatory reply within two months.
Employers, Portuguese ones especially. Many local companies have for years paid people in identical positions very differently, for historical reasons: who joined when, and who negotiated how. Publishing ranges would force them to level that out immediately and in public. The delay gives them time to do the same thing quietly.
And Who It Won’t Help
Anyone looking for their first job in Portugal. You are still applying blind, with no sense of the local ranges, and you risk spending weeks on a process that ends in an offer of 1,200 euros gross. For someone with no local background, the most serious loss here is not the money but the time.
Employees of companies with fewer than 50 people. Startups, agencies, small businesses — where a sizeable share of expats work — fall outside most of the new obligations altogether.
Freelancers on recibos verdes. The directive regulates employment. It does not apply to independent contractors in any way — neither the bans nor the rights.
What to Do Right Now
Don’t answer the question about past pay. Even before the law passes this is a perfectly normal negotiating position; now it is a right protected directly in law. A form of words that works: “My previous salary was in a different country and a different market — let’s discuss the range for this position.”
Ask about money on the first call. In Portuguese hiring culture this is still considered slightly awkward. But the law, even in its current wording, establishes your right to know the figure.
Collect benchmarks yourself. Annual salary surveys from recruitment firms, sector reports on the IT market, collective agreements for your industry — until ranges are published, this is the only substitute.
If you work at a company of 50 or more, try the request. Once the law is in force, a written application for the average pay levels for work of equal value becomes your right, with a fixed deadline for the reply.
The law has not been passed yet: the draft has been through public consultation and still has to clear parliament and the president, and the wording may change. Lawyers point out that even the current version transposes the directive only in part — the procedural safeguards have been left out of it. Which means the subject will almost certainly have to be revisited, and we are following it.
If you have had an offer marked down because you had just relocated, or any other work-related story from Portugal, write to us at welcome@xpat.land.
