EU Pay Transparency: No Time to Lose!

It’s 2025! And that means June 7, 2027 is getting closer. Why is that date important? It’s the final date to submit your first corporate pay transparency report. Now you might say, that’s still two and a half years out, so why the rush? Well, you must report on 2026 pay and compensation data. Which means that whatever remuneration changes you make this year will be the basis to determine your pay gap. And I hope that you already know what the current gender pay gap is…

But what if your country has not released it’s local pay transparency legislation yet? Should you not wait to implement until you know exactly what you are supposed to do? No you should not, and here are 5 questions and answers to explain what you should do instead!

1. Which countries have released a localized version of the EU Pay Transparency Directive?

There are three countries that have released draft legislation: Sweden, Belgium (Fédération Wallonie-Bruxelles) and Poland. Countries have until June 2026 to transpose the Directive into national laws. But I promise you that if you delay the implementation until July 2026, you will not have enough time to finish this project before the reporting deadline. Unless you are a small, single country employer.

2. My country has not yet released the localized version. What should I do?

It’s frustrating to have to wait for local legislation when you want to get started. But I suggest you familiarize yourself with the core principles of the EU Pay Transparency Directive as they apply at the EU level. The legislative documents are available in the 24 official languages of the EU and the document is not very long.

The EU Pay Transparency Directive provides a clear framework of pay transparency and equity goals. Even without the national version, it is wise to start implementing the general principles, such as equal pay for equal work, documenting pay structures, and addressing any visible pay disparities.

You can start by working on your internal pay gap analyses, by collecting relevant data and creating or reviewing frameworks (job architecture, salary bands) that will allow you to comply once the local regulations are clear. Early preparation ensures that when the local version of the directive is released, your organization will already have the basics in place.

3. Is it possible to prepare for the EU Pay Transparency Directive before the country-specific rules are available?

Yes, you should start preparing now, even without the localized version. The goal is clear: the gender pay gap and the gender compensation gap should be below 5%. Begin by organizing your core employee data: PII, payroll, time, benefits and compensation information. Follow that up by conducting an internal pay audit to determine if and where you have pay gaps. Create a plan to mitigate the gaps before the end of 2026. Once that is done, start analyzing your pay practices to identify how you can prevent gaps from happening in the future. This proactive approach ensures that when the specific regulations are introduced, your organization is already aligned with the directive’s spirit. Additionally, you can start communicating with legal experts to anticipate how the national version may adapt the EU rules and plan accordingly.

4. What are the potential consequences of delaying the implementation until the local legislation is available?

Implementing pay transparency is a big project! It requires quite a few steps (see the picture). And while you might already have a number of steps done, I am pretty sure that you don’t exactly know the current gender pay gap in your organization. And especially if you have to submit your proposal to the works council or union, the sooner you start, the better it is.

But pay transparency is not something you only do to adhere to legislation. As evidenced by companies that already put pay transparency in place: it demonstrates that you are a fair and equitable employer. Even if your country has not yet released its localized guidelines, delaying action can still result in missed opportunities. Not only could your organization risk falling behind once the regulations are released, but you could also miss out on the broader benefits of pay equity, such as improved employee engagement and reputation in the labor market. And when you wait for the localized version, that may also lead to a rushed implementation because of the June 2027 deadline, potentially increasing the likelihood of non-compliance or mistakes. The direction is clear, so start preparing today!

5. How can you stay updated on when the localized version of the directive is released?

There are several websites that track the release of local pay transparency legislation: Syndio has a good one with links to the draft legislation documents. You can also monitor local government and regulatory bodies’ websites, subscribe to relevant newsletters, and consult with legal or compliance experts who track such developments. And interest in pay transparency webinars and keynotes is rising as well. Which means that attending industry webinars or networking events can also provide valuable insights into local interpretations of the EU directive as it is being adapted to national law.