The EU Pay Transparency Directive (PTD) is not just another compliance exercise. It represents a fundamental shift in how employers disclose, justify and defend pay practices across the EU. Following on from our 2026 trends report, we are diving into the topic of pay transparency and equal pay with a series of blog posts.

As pay practices become increasingly transparent and legally contestable, employers will face a revolution that will accelerate equal pay enforcement and potentially fuel group workforce litigation. In this first blog post, we focus on a few aspects of this revolution.

From transparency to equal pay

At its heart, the PTD is designed to enforce the principle of equal pay for equal work or work of equal value – a cornerstone of EU labour law that, despite having long-standing legal standing, has proved difficult to enforce in practice. The PTD’s pre-employment and workforce disclosure requirements include the following.

• Employers must provide salary information (starting pay or pay range) to job applicants before the interview or at the earliest practicable stage.
• Employers are prohibited from asking applicants about their current or previous pay, a shift designed to prevent historical pay discrimination from seeping into future offers.
• Current workers and their representatives gain rights to access average pay levels broken down by gender for comparable roles, and access to the criteria used to determine pay and progression.
• Employers must ensure vacancy...

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