{"id":8656,"date":"2025-05-14T15:04:59","date_gmt":"2025-05-14T15:04:59","guid":{"rendered":"https:\/\/www.brightmine.com\/us\/?post_type=resources&p=8656"},"modified":"2025-05-30T15:05:31","modified_gmt":"2025-05-30T15:05:31","slug":"eu-pay-transparency-dont-wait-to-prepare","status":"publish","type":"resources","link":"https:\/\/www.brightmine.com\/us\/resources\/hr-compliance\/pay-transparency\/eu-pay-transparency-dont-wait-to-prepare\/","title":{"rendered":"EU Pay Transparency: Don’t Wait to Prepare"},"content":{"rendered":"\n
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Published: 14 May 2025 | by Emily Scace<\/strong>, Brightmine Senior Legal Editor<\/p>\n\n\n\n

In May 2023, the European Parliament adopted a directive<\/a> (2023\/970) aimed at advancing pay equity and increasing pay transparency. The 27 member states of the European Union have until June 7, 2026, to enact and implement national legislation carrying out its requirements.<\/p>\n\n\n\n

As of May 2025, just five member states – Belgium, Ireland, the Netherlands, Poland and Sweden – have drafted legislation to transpose the directive. Yet employers with an EU presence should not take the slow rollout as a license to delay preparations. The implementation date is approaching fast and implementing a pay transparency and pay equity strategy takes time. Employers that wait risk finding themselves rushed and out of compliance when deadlines arrive.<\/p>\n\n\n\n

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Even when implementation is complete, EU member states will not have identical requirements. While all member states must adopt the directive’s minimum requirements, some will opt to exceed these standards, and countries with existing equal pay and pay gap reporting legislation may take a different approach than those starting from scratch. Yet all national legislation must address the same core elements, and employers need not wait for final details of each member state’s approach to begin their own preparations.<\/p>\n<\/div>\n\n\n\n

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“All national legislation must address the same core elements, and employers need not wait for final details of each member state’s approach to begin their own preparations.”<\/p>\n<\/div>\n<\/div>\n\n\n\n

Along with tracking progress towards implementation <\/a>and details in EU member states of interest, employers should begin by addressing these core elements:<\/p>\n\n\n\n

Pay Transparency and Recruiting Practices<\/h2>\n\n\n\n
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  1. Provide job applicants with a pay range for positions for which they have applied. This information must be provided in a manner that ensures “an informed and transparent negotiation on pay, such as in a published job vacancy notice, prior to the job interview or otherwise.” Note that some member states may take a stricter approach to this requirement by requiring all job postings to contain a pay range.
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  2. Do not inquire into applicants’ pay history with their current or previous employers.
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  3. Ensure that job titles and job vacancy notices are gender-neutral.
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  4. Conduct all recruitment processes in a nondiscriminatory manner.
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  5. Make the criteria used to determine workers’ pay, pay levels and pay progression – which must be objective and gender-neutral – easily accessible to employees. Individual EU member states may choose to exempt employers with fewer than 50 workers from this requirement.
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  6. Provide information to employees annually on their right to receive information about their individual pay level and the average pay level, broken down by sex, for workers performing comparable work, and the steps to exercise this right. Respond to a request from an employee to receive this information no later than two months from the date of the request.<\/li>\n<\/ol>\n\n\n\n

    Pay Gap and Demographic Reporting<\/h2>\n\n\n\n

    Begin collecting information on the organization’s gender pay gap and workforce gender composition in preparation for reporting to the applicable government entity.<\/p>\n\n\n\n

    The directive specifies the following phased-in reporting schedule:<\/p>\n\n\n\n