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Pay Transparency Directive

Equal pay: new rules on pay transparency in the EU

In recent years, the European Union has been consistently striving to improve the conditions of employees in the labour market. One of the new directives that will have an impact on companies and their employees as well as job applicants is the Directive on gender pay transparency. From mid-2027, the Directive will require companies to report gender-related data on pay equality and will also require them to be able to transparently inform their employees and candidates about the salary level for a given position. Overall, the Directive brings with it a number of issues and challenges that we need to start preparing for as soon as possible. 

Everything you need to know about Pay Transparency Directive (PDF) >

Our services

As part of this comprehensive project, we will help you with: 

  • Review and updates of the job architecture and its catalogue;
  • Evaluation and grading according to the Deloitte methodology, which will then be retained for future use;
  • Benchmarking and setting up remuneration bands for individual grades/job families;
  • Identifying outliers and setting up a pay alignment strategy;
  • Designing a methodology to justify any pay differentials (number of years on the job, education, overtime, performance, etc.) for EU Pay Transparency reporting purposes;
  • Setting up governance for the EU Pay Transparency Directive for all HR processes; 
  • Taking into account the obligation of transparent communication within the recruitment process and within the company and towards employees.

What obligations does the Directive entail?

The Directive imposes four basic obligations on companies:

Under the Directive, employees will have the right to be informed of their individual remuneration level and of the average remuneration levels broken down by gender for categories of workers who perform the same work or work of equal value as them.

The Directive also implies a requirement to inform applicants of the starting remuneration level for the job or the pay range. In doing so, the information will have to be provided to the candidate without them having to ask for it, “for example, in a published vacancy notice, before the job interview or in any other way”.

Under the Directive, employers will also be obliged to provide the state with a range of information relating to salaries and the gender pay gap. The average gender pay gap for each category of employee should not exceed 5% per employer. If this is the case, the employer will be obliged to justify and remedy the pay gap.

The employer is obliged to undertake a joint remuneration review to address and remedy the pay gap in cooperation with the employees if:

  • The remuneration report shows an average gender pay gap of at least 5% for any category of workers;
  • The employer has failed to justify the difference in average remuneration levels on objective and gender-neutral criteria;
  • The employer has not corrected the unjustified difference in the average remuneration level within six months of the date of submission of the remuneration report.

During a joint remuneration review, the employer and the employee representatives should first identify the pay gap and the reasons for it. Subsequently, remedy the differences and take measures to prevent them.

Who will be affected by the Directive and from when will reporting be mandatory?

The new rules will affect all employers regardless of their size. Member States are required to implement the Directive by June 2026

Under the Directive, gender pay gap reporting will only apply to companies with 100 or more employees (however, the Czech legislator may also impose obligations on smaller companies). The frequency of reporting and the deadline for submitting the first report will vary depending on the size of the company. Companies with more than 150 employees will be obliged to submit data on the gender pay gap in 2027, but data for 2026 will already be reported.

What will all be affected by the Directive?

Job architecture and evaluation

It will involve the creation a fair and comprehensive system for evaluating and comparing categories of activities, as well as setting up a monitoring process and creating appropriate job descriptions.

Wage setting and remuneration strategy

It will involve identifying of the pay gap and qualitative justification of the difference, deciding on possible changes of pay bands and the performance appraisal cycle and establishing criteria for pay bands changes.

Recruitment and selection of suitable canditates

It will concern setting up a process for informing applicants about the salary range, adressing any tension from existing employees, adjusting contracts, guidelines and documents and also training for hiring managers.

Documentation and communication

It will involve documenting the process of deciding on pay bands, setting up a reporting process and ensuring appropriate communication to employees, candidates, government authorities and other stakeholders.

Is the gender pay gap in your company below 5%?

Let your employees and applicants know and be a certified fair employer. Get in touch with us and we will help you achieve the European Fair Pay Innovation Lab certification.