Compversation #28 - Are you procrastinating?

Procrastination is a desperately human strategy.

I say strategy because it gives us the illusion of saving time — when in fact, it does the opposite. Contrary to popular belief, it’s not about laziness or disorganisation.

When we put off a task, we know, rationally, that we’re making life harder for ourselves: sooner or later we’ll have to do what needs to be done, only this time under pressure and stress.

But despite all our reasoning, part of our brain is convinced that procrastinating helps us conserve energy. That’s especially true when we’re uncertain about the task itself — when instructions are unclear, when we don’t know which direction to take or where to start. 

Psychologists call this task ambiguity. When a task feels ambiguous, rather than risk wasting effort, we prefer not to act at all.

Don’t worry, I haven’t decided to change this newsletter’s editorial line for the new season. I’m not suddenly becoming a motivational coach: this will still be about compensation.

But over the past few months, I’ve noticed that these behaviours we all know on an individual level are being replicated almost identically inside organisations. For example: we all know that the deadline for implementing the EU Pay Transparency Directive is coming in June 2026, yet very few companies have started to prepare.

I can’t help but wonder if this stems from perceived ambiguity: as long as no draft law has been presented to parliament (depending on your location!) we tell ourselves we don’t have enough information to act. And we tell ourselves there’s still plenty of time before we need to get started.

But that’s an illusion: the EU directive deadline is coming, regardless of what’s happening on a global or political scale. 

And more importantly, companies already have (almost) everything they need to move forward. This newsletter focuses on the upcoming transposition of the EU Pay Transparency Directive and how different countries are dealing with their pay transparency laws.

Where are we in the transposition process? 

At the end of last July, I had the opportunity to be invited to the French Ministry of Labour by the team in charge of implementing the EU Pay Transparency Directive. I was able to share my perspective on the challenges ahead and relay the feedback and questions I regularly hear from HR Directors and Compensation and Benefits professionals. 

What struck me the most was how much progress we’ve made and how detailed the European directive actually is. As Anita Lettink wrote recently in her newsletter on the topic: “You only have to read it to know what to do.” The vast majority of obligations are already known. 

In fact, the eight European draft bills available so far contain no surprises. If anything, the countries that have already started implementing them are being even more demanding than the directive itself.

For example, some, such as Sweden, are extending pay reporting obligations to companies with fewer than 100 employees, even though this isn’t required under the EU text.

At Figures, we’re closely tracking the evolution of these national transpositions across Europe — you can find a detailed summary in our dedicated report. 

Of course, some uncertainties remain, and will continue to do so until the final law is adopted.

For example:

• What’s the minimum sample size needed to compare one’s pay to that of colleagues? Finland, for instance, hasn’t specified one, meaning that in a company where only two employees hold the same position, if one requests a comparison, they could immediately infer the other’s salary.
• What obligations will apply to smaller companies, with fewer than 100 employees, that are, in principle, outside the directive’s scope?
• Will there be limits on the size of the salary ranges companies must disclose to candidates?
• Will employee share ownership plans fall within the law’s scope?

These are fascinating discussions, and I plan to dedicate the next few editions of this newsletter to the last two questions.

Why companies resort to doing nothing 

Despite the unanswered questions, the content of the upcoming law is already clear enough for companies to start taking action.

A recent survey by Robert Walters found that only four in 10 companies feel ready for the transposition of the directive. That number already seems optimistic to me: based on my conversations with Compensation and Benefits professionals, I’d estimate that closer to 5-10% of companies are truly prepared.

This inaction can create a vicious circle. Companies look around and see that no one else is taking the lead, so they don’t bother either.

Beyond this herd effect, there are several reasons why companies may choose to take refuge in inaction.

• Some simply aren’t aware of the upcoming legislation, though these are becoming fewer and fewer.
• Others are aware but remain somewhat cynical, assuming that the law won’t change much in practice and will just be another mandatory reporting exercise.
• A larger group wants to take action but lacks the time, budget, or internal sponsorship to do so.
• And finally, the most advanced companies, those that have the time, budget, and sponsorship, are realising the scope of the challenge is far broader than they expected. 

Transparency isn’t just about reporting; it requires launching other major initiatives, such as job classification, pay policy reviews, and internal equity audits.

What all these categories have in common is the same thought process: as long as the rules aren’t clear, in black and white, there’s enough uncertainty to justify putting things off until tomorrow. 

Early movers stand to gain 

I don’t want to sound alarmist.

Like Anita Lettink in her newsletter, I believe there’s still no reason to panic. You’re probably not behind, but it would be unwise to wait until the draft law is published to start taking action.

All the more so because being an early mover on this topic can make a real difference when it comes to employer brand and employee engagement.

Even though some details are still being finalised, such as how salary ranges or stock options will be handled, I can’t imagine a single scenario where companies would regret working on:

• An audit of their current situation and the historical pay decisions they’ve inherited
• A clear job and role classification framework
• A review of the overall pay policy
• Training managers on transparency and pay equity topics

These are all foundational projects. But because getting started can be difficult, the Figures team has put together a comprehensive step-by-step checklist to guide you through the process.

As for the uncertainties that remain, I’ll dedicate the next two editions of this newsletter to the questions of salary ranges and stock options.

In the meantime, my inbox is open if you’d like to discuss. 

To continue the conversation 

Here’s a selection of articles to keep the conversation going. Feel free to send me any pieces you’ve found insightful!

EU Pay Transparency Directive: The current status and how to prepare — Morgan Lewis

A clear and practical overview of the directive’s main provisions, timelines, and employer obligations. The article also offers guidance on what HR and reward teams should be doing now to get ready for implementation.

EU Pay Transparency Directive: Updates on implementation across member states — The National Law Review

A recent update on how various EU countries are progressing with transposing the directive into national law — highlighting similarities, differences, and potential compliance challenges for multinational employers.

UK workers back mandatory reporting of disability and ethnicity pay gaps — Mahalia Mayne, People Management (CIPD)

A fascinating development from the UK, where employees overwhelmingly support mandatory reporting of pay gaps related to disability and ethnicity. The country led the way on gender pay gap reporting, and this momentum could signal a broader shift toward wider pay transparency across Europe.