Step 3 to EU pay transparency: reviewing recruitment processes for compliance

As part of the EU pay transparency directive, organisations across EU member states must take a closer look at how they attract and hire talent. This includes updating recruitment workflows to meet new requirements and support fair pay practices.
Under the directive, businesses must include salary ranges in job advertisements and avoid using a candidate’s salary history as a benchmark. These transparency measures are designed to reduce pay discrimination and support equal pay for equal work. They also shift the burden of proof toward employers, requiring clear documentation of pay decisions and transparent pay information.
To comply, HR teams must review and redesign recruitment processes, pay policies and pay practices. This includes aligning job descriptions, job titles and job levels with your broader job architecture to ensure consistency and fairness across categories of workers.
What does a compliant recruitment process involve?
Updating recruitment processes for compliance involves several key actions:
- Including salary ranges, base pay and pay progression details in all job postings
- Removing questions about salary history and pay history from application forms and interviews
- Ensuring job descriptions reflect gender-neutral criteria and work of equal value
- Aligning job titles and job levels with your job architecture and pay structures
- Documenting pay decisions and metrics used in candidate evaluation
- Training hiring managers and talent acquisition teams on the directive’s mandates
- Engaging workers’ representatives and stakeholders in policy updates
- Reviewing employment contracts to ensure consistency with pay transparency laws
- Ensuring salary information and pay ranges are communicated clearly to job seekers
These changes also support broader DEI initiatives and help organisations build trust with job applicants. They contribute to gender pay gap reporting and help reduce disparities in average pay across job families and functions.
Organisations must also ensure that individual pay decisions are based on objective criteria and not influenced by pay secrecy clauses or historical discrepancies. This is essential for meeting reporting obligations and avoiding non-compliance under national law.
In some cases, organisations may need to conduct a pay assessment or pay audit to identify pay differences and back pay liabilities. These actions support the principle of equal pay and help ensure compliance across all member states of the European Union.
Key talent to lead recruitment compliance
To implement these changes effectively, organisations need HR professionals with expertise in policy, compliance and talent strategy. Here are the roles to prioritise:
HR Policy and Compliance Specialist
These professionals ensure recruitment processes align with employment law and the EU directive. They lead policy reviews, update documentation and advise on legal risks related to pay transparency laws.
Skills required
- Strong understanding of employment law and regulatory frameworks
- Experience with policy development, pay audit and compliance reviews
- Ability to engage stakeholders and workers’ representatives
Download our salary guides for benchmarking and expectations.
Talent Acquisition Lead (with compliance experience)
These professionals oversee recruitment strategy and ensure hiring practices support equal pay and pay equity. They work closely with HR leaders to embed compliance into every stage of the recruitment process.
Skills required
- Experience with recruitment operations, employer brand and DE&I strategy
- Knowledge of pay transparency laws and gender pay gap reporting
- Familiarity with platforms like LinkedIn and applicant tracking systems
Download our salary guides for benchmarking and expectations.
Where to find the right talent
The best candidates for these roles are often leading change within their current organisations. They understand the complexity of recruitment compliance and the importance of aligning hiring practices with business strategy. That’s why working with a specialist HR recruitment consultancy like Frazer Jones is essential.
We have deep networks across Europe and the European Union and we actively engage with professionals on platforms like LinkedIn. Whether you’re hiring for a permanent role or need interim support, we can help you find the top talent to lead your compliance roadmap.
We also host webinars and publish insights to help HR teams stay ahead of evolving pay transparency regulations and reporting requirements.
In some cases, considering an interim role is the most effective way to approach compliance with the directive. An experienced HR professional with the right skillset may only be needed for a short period while the business is made compliant. If your existing HR team is strong, long-term support may not be necessary. We’re now equipped at Frazer Jones to provide top interim talent in Europe, helping businesses access flexible expertise exactly when they need it.
Reviewing recruitment processes is a vital step in meeting the mandates of the EU pay transparency directive. It helps organisations reduce pay inequalities, support fair pay and build a more inclusive hiring experience. By investing in the right talent and tools, HR leaders can ensure their recruitment strategy is both compliant and competitive.
Need help hiring for your recruitment compliance team?
