With the 7 June 2026 deadline for transposing the EU Pay Transparency Directive (EUPTD) into national law fast approaching, some organisations may be tempted to wait for local legislative details before acting. However, the European Commission’s recent response to speculation about potential delays is clear in its commitment to effective and timely implementation. Member States are still expected to deliver on time, with the Department of Children, Disability and Equality currently developing local guidance. For employers, proactive preparation is essential.
Raising the bar
The EUPTD represents a significant shift in how organisations must approach pay equity, transparency and reporting. Building on the foundations of existing gender pay gap reporting. These include:
Mandatory disclosure of salary ranges in job advertisements and during the recruitment process
Employee rights to pay information, including individual and average pay for equivalent roles.
Gender-neutral job evaluation and classification systems that require objective, auditable criteria for pay decisions.
Joint pay assessments where an unexplained gender pay gap of 5% or more persists.
Significant legal and reputational risks for non-compliance, including fines, compensation claims and public scrutiny.
In response to calls for flexibility or delay, the European Commission has reaffirmed its commitment to the Directive’s timeline. The expectation remains that all Member States will have transposed the Directive by June 2026, with the first mandatory disclosures due in 2027 for larger employers.
The Commission has also signalled that it will provide additional guidance and toolkits, but these are intended to support, not substitute, timely compliance.
For employers, this means the window for preparation is now. Waiting for national legislation or further clarification is a high-risk strategy that could leave organisations scrambling to catch up, or worse, exposed to compliance failures.
What early preparation looks like in practice
Organisations that are making steady progress on pay transparency are focusing on practical steps:
- Conduct a comprehensive assessment of job structures, pay policies and data readiness.
- Develop or refine a gender-neutral job evaluation method, based on objective criteria and applied consistently across the organisation.
- Update recruitment and pay policies to ensure transparency in pay setting, progression and recruitment decisions.
- Implement systems and data controls to support accurate reporting and timely responses to employee information requests.
- Establish clear governance and escalation protocols for joint pay assessments and ongoing compliance monitoring.
- Invest in communication and training to embed transparency into organisational culture and equip leaders to respond confidently to employee queries.
Our experience supporting clients through regulatory change, most recently with gender pay gap and sustainability reporting, has shown that early, structured action delivers the best outcomes and mitigates risk.
Organisations that are prepared avoid rushed job evaluation, inconsistent decisions and reactive fixes. The focus is less on a one-off exercise and more on putting workable structures in place before they are tested by employees, regulators or the public.
The bottom line is that the EU Pay Transparency Directive is not just another compliance exercise. It is an opportunity to build trust and drive cultural change. The direction of travel is clear and the time to act is now.
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