EU Pay Transparency Directive: 4 Essential Actions to Take Now

The EU Pay Transparency Directive will reshape how organisations define jobs, make pay decisions and report on fairness. It goes far beyond publishing pay ranges in job adverts. Employees will have the right to understand how pay is determined and to request information on average pay levels for people doing the same work or work of equal value. Employers will also need to report on gender pay gaps and address any unjustified differences. 

With some countries moving early and others delaying implementation, the timeline may feel uncertain. But as we discussed in our recent webinar, waiting for perfect clarity isn’t an option. The work needed to get ready is substantial and needs to start now. 

Here are the four priority actions we recommend every organisation focuses on: 

1. Create your ‘category of worker’ job groupings 

The EU Pay Transparency Directive revolves around the concept of categories of workers performing the same work or work of equal value. This is the basis for reporting and for employees’ right to request information. 

To meet this requirement, you’ll need a clear, current job architecture — a framework that groups, aligns and manages jobs using objective criteria. Without it, it will be difficult to identify comparable roles or explain pay differences. 

Start by reviewing and harmonising your job families, levels and grades. Map every employee to a job and retain historical versions for future comparison. Audit your job descriptions to ensure they’re complete, consistent and governed. 

2. Establish a robust, bias-free way to value jobs 

Once your job architecture is in place, the next step is to ensure you can explain why jobs are paid differently. 

The EU Pay Transparency Directive requires employers to use objective, measurable and gender-neutral criteria to determine pay and progression. That means introducing or strengthening your job evaluation and levelling framework so that roles are assessed consistently across the organisation. 

A structured approach should include analytical factors such as effort, skills, responsibilities and working conditions. Link evaluation results to pay bands and make your progression criteria clear and visible. Employees should be able to see how pay increases within and between levels and understand the rationale for decisions. 

Article 6 of the EU Pay Transparency Directive goes further, requiring employers to make these criteria easily accessible. Transparency about how pay is determined is as important as the numbers themselves. 

A bias-free process for valuing jobs doesn’t just meet legal requirements; it builds trust and confidence in how pay and progression are managed. 

3. Define your pay elements and communication strategy 

The EU Pay Transparency Directive defines pay broadly, including salary, bonus, allowances and benefits in kind. Organisations will need a complete and connected picture of all elements of pay, not just base pay. 

Start by creating a pay element dictionary that captures every component and how it’s valued. Understand where data sits — in payroll, HRIS or benefits systems — and bring it together. Analyse base, variable and complementary pay separately before combining them into total pay. 

Once you have clarity on what’s included, focus on communication. Decide how transparent you want to be and plan your messaging accordingly. Some organisations will provide annual pay and progression statements to all employees. Others will respond to requests. 

The EU Pay Transparency Directive should be about clarity, not confusion. The more context you provide, the easier it is to build trust in your pay practices. 

4. Prepare for reporting and remediation 

The EU Pay Transparency Directive introduces new public and internal reporting requirements. Company-level reporting will include mean and median gender pay gaps and pay quartiles. Internally, you’ll need to analyse and explain gaps by category of worker. 

If the pay gap within any category exceeds five per cent and cannot be justified by objective, gender-neutral criteria, employers must act to close it. 

To prepare, review your current reporting capabilities, run early test analyses and identify where pay gaps exist. Develop a remediation plan to address any unjustified differences before your first official reporting year. Remember that 2027 reporting will use 2026 data, meaning you have a little over a year to get ready. 

Getting your house in order for the EU Pay Transparency Directive

Each of these four actions depends on one thing: solid job data. Without a consistent, governed foundation of job information, it’s impossible to group roles, evaluate jobs, analyse pay or report accurately. 

This is exactly where Rolemapper can help. Our job architecture and job description management platform provides organisations with the data foundation they need for transparency and compliance with the EU Pay Transparency Directive, including harmonised roles, levelling, and clear progression criteria. Using AI-enabled tools, we help you quickly build or update your job architecture, create job groupings and standardise profiles so you can report with confidence. 

Whether you’re modernising an existing framework or starting from scratch, we can help you get your house in order ahead of 2026.