In a months’ time, hiring across the EU changes permanently. If you hire into Berlin, Madrid, Milan or any other European location, the directive applies to you. Regardless of where your business is headquartered.
At Solutions Driven, the conversations we are having with hiring teams across the UK and Europe right now point to the same blind spot: most hiring managers know “something is changing” but have not yet rewritten their job ads, briefing templates or interview scripts. With the deadline a few weeks away, the runway is short.
What is the EU Pay Transparency Directive?
The EU Pay Transparency Directive – formally Directive (EU) 2023/970 was adopted in 2023 and must be transposed into national law by every EU member state by 7 June 2026. Some countries are going further than the minimum, if you hire across multiple EU countries with one process, you will need to follow the strictest country’s rules – meeting the EU minimum won’t be enough.
The moment you hire into an EU member state – a German Engineer, a French Executive or an Irish Operations Manager, it applies to you.
6 Key Changes Hiring Managers Should be aware of
1. Salary ranges must be disclosed before interview
Employers must give candidates the salary range before the first interview. The directive requires disclosure “in the job vacancy notice or otherwise prior to the job interview” either the advert or pre-interview comms is acceptable. In practice, multi-country employers are putting ranges directly in the advert to keep processes consistent and reduce risk.
2. Asking about salary history is banned
Article 5(2) prohibits employers from asking candidates about current or previous salary. This covers direct questions (“What are you on now?”) and indirect attempts to find out pay history. Candidates may volunteer the information, but you cannot ask. If a candidate asks “Can you match my current salary?”, the response must explain the band and the criteria for positioning within it, not probe what they earn.
3. Job ads and titles must be gender-neutral
Pay structures must be set on objective, gender-neutral criteria like skills, responsibilities, experience and the language in adverts and titles must follow suit. Wording that anchors pay informally to what the previous postholder earned is no longer defensible.
4. Pay-gap reporting becomes mandatory for larger employers
Employers above the size threshold must report on their gender pay gap. If a gap exceeds 5% and cannot be justified, the employer is legally required to take corrective action. In several member states, the data will be publicly available.
5. Employees gain a new right to pay information
Workers can request information on their own pay, plus the average pay levels broken down by gender for colleagues doing the same job or work of equal value. In practice, salary information you have historically kept internal is now legally disclosable on request.
6. The burden of proof shifts to the employer
In pay discrimination disputes, the burden of proof now sits with the employer, not the employee. Combined with new sanctions – fines, back pay, interest and other national remedies – the cost of getting this wrong has materially increased.
Tackling A Key Issue In The Workplace
For years, one of the quietest but most damaging problems in hiring has been the pay gap between new joiners and existing employees. To compete for talent, companies have stretched budgets to bring people in while the people already on the team, often delivering more, stayed on older pay bands. Trust erodes, engagement drops and your best people quietly disengage or start answering LinkedIn messages from recruiters.
The EU Pay Transparency Directive changes that: employees will have the right to request average pay for equivalent roles, pay secrecy clauses will be banned and salary ranges must be disclosed up front. Companies will no longer be able to quietly pay new hires more than existing staff without it surfacing – forcing a long-overdue conversation about internal pay equity and rewarding the businesses that get retention right.
How to prepare before the deadline
1. Replace “competitive salary” and “current salary” wording with documented salary bands. Set each band on objective criteria – skills, responsibilities, experience, not on what the previous postholder earned.
2. Add those bands into your job templates, candidate communications and ATS workflows. Every EU candidate should receive the range automatically before their first interview – not on request.
3. Audit all of your live EU job adverts this week – does each one disclose a range or is the range available in pre-interview comms?
4. Audit pay across roles that do equivalent work. Where you find gaps, work out whether they’re explained by objective factors – skills, experience, responsibility or whether they need fixing.
5. Train your recruiters and interviewers. Out: “What’s your current package?” In: “Here is the band and here is what positions you within it.”
6. If you have over 100 employees in any single member state, get ahead of pay-gap reporting now – do not wait for the first reporting cycle to find the problem.
For Solutions Driven clients hiring into EU member states, we have already adjusted our briefing templates, candidate communications and screening scripts. If your in-house process has not, the gap will show up in candidate experience first and compliance risk second.
Get in touch to see if your processes are compliant with the new standard.
Why this isn’t just a compliance story
It is tempting to file this under “legal team’s problem”. That would be a mistake.
Right-first-time hiring already depends on alignment between brief, market data, candidate fit and motivation. From June, the cost of misalignment is no longer just a slow process, it is a compliance exposure with sanctions attached.
FAQS
Do I have to put the salary in the job advert?
The directive requires disclosure in the advert or before the first interview. Several member states are mandating it in the advert itself, so a multi-country approach should default to advertising the range.
Can a candidate volunteer their current salary?
Yes. The ban is on the employer asking; it does not prevent a candidate from sharing the information themselves.
What are the penalties for non-compliance?
Sanctions include fines, back pay, interest and other remedies under national law. The burden of proof in pay discrimination claims now shifts to the employer.
What is the 5% pay-gap rule?
Employers above the relevant size threshold must report their gender pay gap. If the gap exceeds 5% and cannot be objectively justified, the employer is required to take corrective action.
Do you need help with your next critical hire? Our process is already aligned to the 7 June 2026 directive. If you have a critical EU role to fill, contact us to speak to one of our recruitment specialists today.
