The EU Pay Transparency Directive gives employers across Europe a common starting point, but it doesn’t create one neat set of rules. Each Member State will define important details such as reporting deadlines, pay definitions and enforcement requirements.
Countries are also transposing the rules at different rates. At the time of writing, some (like Italy) already have their new laws in place, while others (like France) are still at the draft stage. In many other countries, the final requirements are still unclear.
This creates an awkward planning problem for multi-country employers. They need to comply with the specific rules in each country. But should they prepare now, even where those rules aren’t fully defined? Or should they treat each national law as a separate project and wait for the law to be finalised before acting?
Neither option is ideal. Multi-country employers need to separate what can be prepared at a cross-country level from what needs to be adapted locally. In practice, that means building shared compensation foundations now, then adding country-level legal detail as national rules become clear.
Multi-country employers can’t wait for full transposition to start preparing for pay transparency
As countries work through the legislative process to get their pay transparency laws on the books, some multi-country employers are finding themselves in an uneven position.
In some countries, new rules are already in force or close to implementation, and larger employers may already need to prepare for first gender pay gap reporting deadlines from 2027. But others haven’t even published a draft law, making it hard to guess what the final rules will look like.
In that context, “wait and see” can feel like the sensible option. Why start building processes before the local rules are clear? But for multi-country employers, waiting creates two practical problems:
- Waiting creates deadline pressure: Companies that don’t start preparing until the rules are finalised in each country will end up scrambling to comply once they’re introduced. This creates pressure for local teams and increases the risk of missed obligations.
- Reacting country-by-country is inefficient: If you treat each national law as a separate implementation project, local teams will end up rebuilding similar workflows, data checks, reporting processes and communication materials. The result is duplicated work and a less consistent approach across countries.
This doesn’t mean trying to prepare everything now, or guessing at country-specific details before they’re confirmed — that’s unlikely to be efficient either. But the Directive does set minimum standards that each Member State must follow, which means some preparation can begin before every local rule is finalised.
Shared baseline, local details
The key to proper preparation is separating what will apply across the EU from country-level differences that may not yet be defined. For example, the Pay Transparency Directive sets the following minimum standards:
- Pay transparency for jobseekers: Employers must give candidates information about the initial pay or pay range for a role, and cannot ask about their pay history.
- Employee rights to pay information: Employees will have the right to request information about their own pay and average pay levels for workers doing the same work or work of equal value, broken down by sex.
- Gender pay gap reporting: Employers above the relevant size thresholds must report gender pay gap data, including gaps in average pay, variable pay and pay by category of worker.
- Joint pay assessments: Employers may need to carry out a joint pay assessment where reporting shows an unexplained gender pay gap above the Directive’s threshold.
- Objective, gender-neutral pay criteria: Employers must be able to show that pay structures are based on objective, gender-neutral criteria such as skills, effort, responsibility and working conditions.
- Work of equal value: Employers need a way to compare roles that may not be identical, but are similar or equivalent in value based on objective criteria.
Understanding this shared baseline means multi-country employers don’t have to wait for every national law before asking some important questions: Do we have reliable pay data? Are our salary bands clear? Can we explain how roles are grouped? Could we respond consistently if an employee asked about pay levels for comparable work?
At the same time, the Directive is not a plug-and-play compliance checklist. Within the Directive’s minimum requirements, Member States still have room to define how those obligations work in practice. For example, many countries will set their own standards for things like:
- Reporting thresholds, processes and formats
- How categories of workers are defined
- Rules for publishing or sharing salary ranges
- The role of worker representatives
- Timelines and processes for employee pay information requests
- Definitions of pay and remuneration
- Sanctions, remedies and enforcement
Country-level differences are already starting to show up in national laws and draft laws. For example:
- France’s draft law would bring reporting into scope from 50 employees, below the Directive’s 100-employee threshold. It would also require pay ranges to appear directly in job ads, rather than allowing employers to provide the information later in the recruitment process.
- In Italy, the law uses two different pay definitions: retribuzione and livello retributivo. Different obligations use different definitions, so employers need to know which pay components belong in each calculation.
- In Poland, the current draft law would require employers to respond to employee pay information requests within 30 days, rather than the two-month maximum set by the Directive.
For more country-specific detail, see our guide to how each Member State is implementing the Directive.
Centralisation vs fragmentation
Multi-country employers don’t need to choose between centralising everything and treating each country as a separate project. The more useful question is: which parts of the work should be prepared once, and which parts need local legal detail?
Here’s what the split might look like:
Getting the balance right is tricky. Too much centralisation and you get processes that look tidy on paper but fall apart on contact with local law. Lean too far into localisation, and you’re back to duplicated work, inconsistent explanations, and a real headache for anyone trying to keep oversight across countries.
Build once, then localise deliberately
Here’s a better model: multi-country employers should take a layered approach: build shared compensation foundations first, then add country-level legal overlays where necessary. For example, you might start by preparing or refining shared compensation foundations like:
- A clear job architecture
- Consistent salary bands
- Reliable sources of pay data
- Systems for pay equity analysis
- Consistent criteria for pay decisions
- Standard workflow principles
Each country can then adapt those foundations to local deadlines, reporting formats, pay definitions and other legal requirements. This allows employers to comply locally without starting from scratch in every country. It also puts teams in a stronger position to adapt when final rules are published in countries where implementation is still pending.
Who needs to be involved?
For most multi-country employers, this work shouldn’t sit with one team alone. Group People or C&B will usually own the shared compensation foundations, such as job architecture, salary range methodology, pay data and pay equity analysis. Local HR and legal should sense-check how those foundations apply in each country, especially around deadlines, employee requests, worker representatives and communication requirements. Payroll and finance may also need to weigh in where reporting data, pay components or budgets are involved.
Checklist: What multi-country employers can do now
At this stage, the priority is not to complete every country-level task, but to organise the work so teams can move quickly as national rules become clear.
Here’s what to do now:
☑ Create a country-by-country tracker to stay aware of national implementation
☑ Separate the work into group-level foundations and country-level legal detail
☑ Assign ownership between People/C&B, local HR, legal, payroll and finance
☑ Decide which templates, workflows and data models should be created centrally
☑ Decide which items need local validation before rolling out
☑ Set a review rhythm to adapt processes as national laws are adopted or amended
☑ Identify countries where compliance work needs to start first because rules are already in place or deadlines are coming soon.
Pay transparency works better with shared foundations
Multi-country employers should not wait for every country to finish transposition before acting. But they also should not treat each national law as a whole new project.
The more sensible approach is to start with the compensation foundations that will be needed across countries. Once this is in place, employers can adapt the legal details country by country as national rules become clear.
All of this requires reliable pay data, consistent salary bands, clear job architecture and workflows that can support both group-level consistency and local compliance. Figures helps compensation teams build those foundations, from salary bands and pay equity analysis to the data and workflows behind employee pay information requests.
Learn how Figures could help you prepare for pay transparency.
