Preparing for EU pay transparency: key focus areas and the talent you’ll need

Author Clair Schindler
August 21, 2025

Last quarter, we hosted a highly engaging event in Dublin: “EU pay transparency, a practical playbook for HR leaders.”

The turnout and discussion made one thing clear: many organisations across EU member states are still in the early stages of preparing for the EU pay transparency directive. With the directive set to be transposed into national law by June 2026, now is the time to act.

This legislation will reshape how businesses approach pay equity, pay levels, and working conditions. But it’s not just about avoiding non-compliance, it’s about building trust, fairness and transparency into the fabric of your organisation.

To support a successful transition, HR teams must focus on four core areas. Each one demands specific expertise and leadership. In this article, I’ll introduce these areas and the key talent you’ll need to lead the way. Over the coming weeks, I’ll explore each step in more detail, so stay tuned!

Step 1: audit existing pay data

Before anything else, organisations need to understand where they stand. A thorough pay audit of current pay structures is essential to identify discrepancies, inequities, and opportunities for improvement. This foundational step ensures that future pay decisions are based on accurate and equitable data.

It also lays the groundwork for gender pay gap reporting, helping organisations meet new reporting requirements and demonstrate their commitment to equal pay for equal work.

Key talent to support this step:

  • Compensation and Benefits Analyst
  • People Analytics Specialist
  • Total Rewards Executive or Manager

Step 2: build a grade and pay banding framework

Creating a transparent and consistent job architecture with clear salary bands and pay ranges helps ensure fairness across roles and departments. It also supports career progression, internal mobility and retention, three areas that are increasingly important to today’s workforce.

This step may also involve a job evaluation process using gender-neutral criteria and objective criteria to assess work of equal value across different categories of workers.

Key talent to support this step:

  • Compensation and Benefits Analyst or HR Business Partner (with compensation expertise)
  • Total Rewards Executive or Manager

Step 3: review recruitment processes for compliance

Under the directive, organisations must include salary ranges in job postings and avoid using a candidate’s salary history as a benchmark. This requires a careful review and redesign of pay policies, pay practices, and recruitment workflows to ensure fairness and legal compliance.

It’s also important to align job descriptions, job titles, and job levels with your broader job architecture to support consistent and transparent pay information.

Key talent to support this step:

  • HR Policy and Compliance Specialist
  • Talent Acquisition Lead (with compliance experience)

Step 4: lead cultural change toward transparency

Pay transparency is not just a compliance issue, it’s a cultural shift. Organisations must foster open communication, build trust and engage employees in meaningful dialogue about pay progression, average pay, and the principle of equal pay.

This step may involve working with employee representatives, workers’ representatives, and other internal stakeholders to co-create an action plan for change. In some cases, a joint pay assessment may be required to address historical pay discrimination or gender pay gap disparities.

Key talent to support this step:

  • Employee Experience or Engagement Lead
  • Chief People Officer or HR Director
  • Organisational Development Specialist or Consultant

Final thoughts

The EU directive presents a unique opportunity for organisations across EU member states to strengthen trust, fairness and employee engagement. By investing in the right talent and focusing on these strategic areas, HR leaders can guide their organisations through this transformation with confidence.

At Frazer Jones, we specialise in helping businesses find the HR professionals they need to lead change. If you’re preparing for transparent pay and want to discuss your hiring needs, we’re here to help. Let’s talk.

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