At a Glance

• In a struggle between data privacy and pay transparency, which prevails? Or are the two concepts at odds at all?

Just when global compliance teams were getting comfortable with the alphabet salad of GDPR (General Data Protection Regulation), a new three letter contender has burst onto the scene: the Pay Transparency Directive (PTD). Even if your organization only has a small workforce in Europe, you will need to get used to this one too.

The deadline for the implementation of the EU Pay Transparency Directive passed on June 7, 2026, although implementation across European member states has been patchy. Only a small number of member states have fully transposed the PTD, some countries have signaled a delay, all while others have provided no update at all.¹

The introduction of the PTD heralds a new dawn in pay transparency across Europe, with binding measures such as broad pay reporting requirements, joint pay assessments, and–of particular interest for this article–the right for workers to request information on individual and average pay levels (the “Right to Information,” or “RTI” to add to your acronym index).

However, this presents a tension:

• The EU loves data privacy; the GDPR has set up a framework of protections and protocols that regulates the processing and disclosing of personal data within the EU.
• Pay information is personal data (albeit ordinary and not special category personal data).
• The PTD wants pay information to be more freely available,...

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