No More Delays!
Your EU Pay Transparency Project Can’t Wait for Perfect Conditions…
I’ve just returned from an October that took me from Paris to London, Frankfurt to Amsterdam, delivering keynotes and workshops on EU Pay Transparency. And everywhere I went, I heard the same refrain: “We’re still in the planning phase.” “We’re waiting for our national legislation.” “We haven’t started yet.”
HR and Payroll friends, we need to talk. Seriously!
June 7, 2026 is your deadline. That’s seven months away. If you haven’t started your project yet, we need to have an honest conversation about what the next seven months need to look like.
Why This Takes Longer Than You Think
Here’s what I’ve learned from organizations who’ve already started: this isn’t a complicated project, but it’s a time-consuming one.
First, there’s the consultation process. If you have works councils or unions, you already know that a “quick agreement” does not exist. These discussions are important and they ‘re supposed to take time, but they can also eat up months of your timeline. Not because anyone is being difficult, but because this is about pay and compensation: it matters! Your employee representatives will have questions, concerns, and valid points that deserve thorough discussion. Maybe even a redraft of your plans.
Then there’s education and communication. Pay transparency isn’t something you can announce in a company-wide email and consider done. Your employees need to understand what a job architecture and salary bands mean, how they can evaluate what “equal work” is, and how to interpret their position within a salary band. Fortunately, most will discover they’re paid fairly, but they need the context to understand that.
And here’s the part that should keep you up at night: this is the first time most of your managers will have to explain pay decisions to individual employees. Your managers will need to discuss not just why someone earns what they earn, but how that compares to the median and mean in their band. With certainty in objective terms. They’ll need to listen with empathy when an employee responds, “But I believe I’m underpaid compared to so-and-so.” They’ll need to handle those conversations with precision (because everything about pay is a dissatisfier!) while maintaining the human connection that makes those conversations productive rather than destructive.
That requires practice. Role-playing. Coaching. Do you feel your managers are equipped to do so, while maintaining employee satisfaction? Or does that mean extra training and thus, extra time?
The Myth of “Waiting for Clarity”
I hear you: “But our national legislation isn’t finalized yet!” Here’s what I’ve said before: the EU Directive is clear enough. Yes, member states will add their own flavors and specifics. But the core requirements? Those aren’t changing. The 5% gender gap? Not going away. You know you’ll need:
- Job classification that supports equal pay for equal work in neutral terms
- Transparent salary bands or ranges
- Pay gap reporting
- Training for managers on pay conversations
- Processes for employees to request pay information
Waiting for your national law is procrastination. And with seven months left, it’s procrastination you can’t afford.
What You Probably Already Have
Here’s the good news I share in every workshop: most organizations are further along than they realize. You likely already have:
- Some form of job architecture (even if it needs refinement)
- Salary data (even if it’s still a bit messy)
- Reporting tools (even if they are not fully adjusted to pay transparency)
- Manager training programs (that can be expanded)
- Employee communication channels (that can be leveraged)
You’re not starting from zero. You’re starting from “we need to organize and formalize what we have.”
Your Action Plan (Starting Today!)
If you haven’t started, here’s what a timeline looks like. I’ve described them in months, but you might have to overlap the periods to be ready by June 7, 2026:
Phase 1: Foundation & Quick Assessment (Month 1)
- Form your core project team (HR, legal, compensation, communications)
- Engage works council/union representatives immediately
- Audit your current job architecture and compensation structure
- Identify critical gaps in your data and processes
- Map your stakeholders and decision-making process
Phase 2: Design & Consultation (Months 2-4)
- Develop or refine your job architecture and salary bands (use what you have, refine as you go)
- Create your pay transparency framework
- Run parallel consultations with works councils and unions (this can’t be rushed, but must start now)
- Design your communication strategy
- Begin drafting manager guidance and FAQs
Phase 3: Education & Preparation (Months 4-6)
- Train managers on pay conversations (start with leadership, cascade down)
- Develop employee education materials
- Pilot your approach with a willing team or department
- Create your request and response processes
- Refine everything based on pilot feedback
Phase 4: Implementation (Month 7 and ongoing)
- Roll out pay transparency tools and information
- Support managers through initial conversations
- Launch employee request processes
- Monitor, troubleshoot, and document learnings
Notice what’s missing? Buffer time. Room for “let’s think about this another month.” Space for perfect conditions. That’s already gone. This timeline is tight but doable, if you start now and maintain momentum.
The Real Cost of Waiting
Every week you delay makes this harder. And here’s what happens when organizations wait too long:
- Consultation becomes a checkbox rather than genuine dialogue, damaging trust with employee representatives
- Manager training gets condensed into a webinar instead of proper practice and coaching
- Communication becomes announcement instead of education, creating confusion and anxiety
- The whole thing feels compliance-driven rather than culture-enhancing
Pay transparency done well is transformational. It builds trust, improves retention, supports equity, and strengthens your employer brand. Pay transparency done in a rush is just… compliance. And compliance done poorly is risk.
If You’ve Already Started: Keep Going
If you’re reading this and thinking, “We started months ago,” excellent. Use the checklist below to confirm you’re on track. Make sure you’re not skimping on manager training or employee education: these are the pieces organizations most often underestimate.
If You Haven’t Started: Start Today
Not next week. Not after the next board meeting. Not when your national legislation is published.
Today!
Pull together your core team. Look at the readiness checklist. Block time on calendars. Send the invite to your works council or union representatives. Begin. You can refine as you go. You can adjust when national legislation adds specifics. But you cannot create time that doesn’t exist. Below, you’ll find three tools to help you get started:
- A Pay Transparency Readiness Checklist – Use this to assess where you are today. You’ll probably be pleasantly surprised by how much you already have.
- A High-Level Project Overview – Use this to map your seven months and identify where you absolutely cannot afford delays.
- Equal Pay for Equal Work – My book describes everything you need to know in detail: from how to create job architectures and salary frameworks to designing your communication approach and what to watch out for.
The Bottom Line
The EU Pay Transparency Directive isn’t going away. Your deadline isn’t moving. And with seven months left, “waiting for clarity” is no longer a viable strategy. The good news? Seven months is enough time to do this properly—if you start now and stay focused. You don’t need to have all the answers today. But you do need to begin the project today.
So finish your coffee, open that checklist, and take the first step! I’ll be here to cheer you on (and answer questions)!
