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Monday, March 31, 2025

Europe – Pay Transparency Directive: preparing for the great unknown? - Employment Law Worldview

Over the last few months, we have done a lot of sessions with clients on the Pay Transparency Directive. Chief among the questions that inevitably comes up is implementation of the Directive in the different Member States. Clients wonder if and how they can prepare for June 2026 when – as per usual – most Member States are nowhere near presenting even draft legislation to translate the Directive into national legislation.

Our response to this entirely sensible question is always the same: while we will of course track local developments and keep you updated, please do not wait until there is more clarity from national legislators to take action on this topic. You don’t have to know about every nut and bolt of the finished product to know enough to start your preparation, especially as the Directive does set out very clear pointers on the likely direction of travel.

One of the main principles of the Directive is that Member States should take the necessary measures to ensure that “employers have pay structures ensuring equal pay for equal work or work of equal value”. These pay structures should be based on a job evaluation scheme which considers skills, effort, responsibility and working conditions (and, if appropriate, any other factors which are relevant to the specific job or position). There is no chance that those key indicators will be altered materially pre-implementation – while it is possible that some states may add further considerations, that will almost...



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