The European Union's (EU) Pay Transparency Directive (the Directive) brings transformational new rights to pay information for employees and candidates beginning in June of this year. The Directive is more than just a regional regulation — it's a seismic shift towards a new era of transparency across the world — impacting every organization that operates in EU member states.
The emerging landscape of pay transparency means employees and candidates are looking for greater trust and understanding in how the organization manages pay. While we hear from Human Resources (HR) leaders that their reward policies and processes are ready for increased scrutiny on the delivery of pay equity, a key challenge is their readiness to foster informed, engaging discussions that address these evolving expectations.
For HR leaders tasked with ensuring readiness for transparent pay communication, two simple actions offer a clear path forward:
Fast-track preparation: There is no need to start from scratch. Deploy best practice content designed to rapidly prepare HR business partners, leaders, recruiters, managers, and employees for transparent conversations.
Empower employees with accessible pay data: Implement a flexible digital platform that clearly provides average pay information, and supporting communication, meeting regulatory requirements and employee expectations for transparency, on-demand.
WTW can help with both. Read on to explore the available content and digital solutions, along with a reminder of the Directive’s requirements.
Responding to the Directive with two key communication solutions
Responding to the Directive with two key communication solutions
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Communication Accelerator Pack
WTW’s Communication Accelerator Pack provides the essential materials employers need to educate key stakeholder groups on the implications of the Directive’s regulations with ease and expertise. It includes materials to ensure:
Strategic alignment:
HR business partner training and master briefing deck for leaders
Operational readiness:
Recruiter guidance and conversation scenarios
Manager guidance on equitable pay and transparent conversations
Manager educational video
Employee engagement:
Employee right to information statement and annual reminder
Employee education (e.g., frequently asked questions and key terms)
Curated by WTW's reward, pay equity and communication professionals, the Communication Accelerator Pack allows employers to save time with expert-vetted, best practice content.
It can be tailored to organization's specific needs, helping to reduce costs and time associated with creating essential communication.
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Pay explained via Embark
The right to request average pay levels for those doing the same work or work of equal value will likely place a significant burden on organizations’ HR business partners, shared services and manager populations. Employees are expected to exercise this right either individually or working with representatives.
WTW’s Embark digital communication platform has a packaged solution for transparent communication. It enables employers to clearly share their pay philosophy, processes, and objective reasons for pay differences, alongside managing individual employee data requests. The platform can also be utilized for gender pay gap disclosure from June 2027 onwards.
While the Directive's immediate impact is on EU member states, the principles of pay equity and transparency are gaining significant traction worldwide. We're already seeing similar legislative movements (disclosure of salary ranges, increased reporting requirements) and growing employee expectations in other countries, companies that get ahead of this curve are viewing this opportunity as a strategic catalyst to mitigate future risks, strengthen their employer brand, enhance organizational trust, and foster a more equitable and engaged workforce.
Reminder of the core provisions of the Directive
The transparency requirements are as follows:
Rights for job seekers from June 2026 (December 24, 2025, in Poland):
All job candidates will need to be told the pay rate/range for the job (in an advertisement or prior to first interview or prior to pay negotiations subject to local legislation).
Employers cannnot ask candidates about their current or previous pay history.
Job vacancy notices and job titles must be gender-neutral and recruitment processes led in a non-discriminatory manner.
Rights for employees from June 2026:
Employers should have pay structures in place to ensure women and men are paid equally for the same work or work of equal value based on objective, gender-neutral criteria.
Employers must make it easy for employees to access information about what criteria are used to determine pay, pay levels and pay progression.
Employees shall not be prevented from (contractually or otherwise) disclosing their pay to others in order to enforce the principle of equal pay.
Employees will have the right to ask for the average total pay of people in the same category of work as them, broken down by gender.
Reporting requirements starting in June 2027:
Organizations with at least 150 workers will need to report their gender pay gap, at an entity level and by category of worker. Over time, this reporting threshold will be lowered to 100 workers (or less depending on local transposition)*.
If there are any gaps of 5%+ by category of worker that cannot be explained with objective reasons, and they have not been remedied within six months after reporting, organizations will need to work with workers’ representatives to conduct a joint-pay assessment and make a plan to resolve them (with employee representatives).
As the June 2026 deadline approaches, the window for proactive preparation is narrowing. We invite you to contact our global experts to discuss how these solutions can be integrated into your pay transparency strategy.
*Entities containing 150+ employees from 2027; and 100+ employees from 2031.
