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Building solid foundations for optimal pay transparency

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Building solid foundations for optimal pay transparency

On June 7, 2026, the European Pay Transparency Directive will come into effect, requiring companies of all sizes to rethink their compensation policies.

On this occasion, Julien Craeynest and Xavier Meulemans are hosting a web series (FR) dedicated to this topic, sharing practical advice to effectively anticipate this new regulation.

This second webinar in the series moves from theory to practice and covers a major step in building your pay transparency policy: preparation. Indeed, it is not just about complying with a new regulation but about creating a robust compensation policy based on reliable data and suitable analytical tools. This preparation is key to ensuring fairness, anticipating market developments, and engaging all stakeholders in a sustainable and transparent approach.

1. Understanding the directive’s stakes

The European directive aims to establish more fairness and clarity in salary formation. It specifically requires:

  • Displaying salary grids,
  • Communicating average salaries by level,
  • Prohibiting the request for candidates’ salary history.

This change goes beyond mere compliance: it represents a cultural shift for companies, which will need to rethink their practices and internal communication.

2. Common mistakes to avoid

The webinar experts have identified several frequent pitfalls:

  • Rushing into compensation without defining the right analysis criteria,
  • Managing the project in secrecy: transparency requires involving management and staff representatives from the start,
  • Neglecting job evaluation: an analytical system based on objective, non-biased criteria is essential,
  • Overlooking communication: it is necessary to engage all employees in the change.

3. Key steps for successful implementation

Audit and validate your data

First, identify your data sources (payroll, benefits, bonuses, etc.) and verify their reliability. Reports based on outdated data risk undermining your initiative.

Implement a job evaluation methodology

Whether you choose an off-the-shelf method or develop your own, prioritize objective criteria, limit their number (max. 9), and weight them according to your organization’s values.

Map and classify jobs

Create a complete mapping of positions, update job descriptions (even through interviews if necessary), and group jobs by family to facilitate comparison.

Define and communicate the compensation policy

Clarify the criteria determining pay (seniority, performance, potential, etc.) and ensure everyone understands them. Procedural fairness—understanding the rules of the game—is essential for the acceptance of pay gaps.

Engage stakeholders

Involve the social and economic committee (CSE), managers, and employees from the start. A coherent and transparent message prevents misunderstandings and promotes buy-in.

4. Governance and continuous adaptation

A classification system must not remain static. Organizations evolve, markets change, and new positions appear… It is crucial to define who is responsible for revising the system and to anticipate future needs for reporting and tools.

Being ahead in pay transparency is a lever for attraction and retention. Communicate openly about your practices, highlight your efforts to candidates and employees, and turn regulatory requirements into a competitive advantage.

Conclusion

Pay transparency is not just a legal obligation: it is an opportunity to modernize your HR policy, build trust, and attract top talent. By following a structured, pragmatic, and inclusive approach, every company can turn this challenge into success.

About our experts

Julien Craeynest is an HR consultant at Arago, specialising in HRIS and Comp & Ben issues. His technical and organisational expertise enables him to support companies in ensuring compliance and optimising their remuneration practices.

Julien Craeynest

Xavier Meulemans is an independent consultant and former Director of Compensation & Benefits and HRIS at international groups. His in-depth knowledge of the strategic and operational challenges associated with salary transparency enables him to decipher its concrete impact on HR policies and social dialogue.

Xavier Meulemans

Frequently Asked Questions - FAQ

Does the directive apply only to the private sector?

No, it applies to both the private and public sectors in the 27 countries of the European Union.

Is seniority considered an objective criterion?

Yes, seniority is recognised as an objective criterion in the analysis of pay gaps.

What should you do if every position is unique in an SME?

Even in small organisations, it is possible to group together positions of equal value according to objective criteria such as level of qualification, expertise or responsibility, regardless of job titles.

Is the collective agreement sufficient to justify the differences?

No. The directive requires a company-specific analytical job evaluation system, in addition to the collective agreement.

What are the risks of non-compliance?

Risks include individual or collective litigation, financial penalties, loss of employee confidence, and difficulties in recruiting or retaining talent.

Does the directive impose collective increases?

Not necessarily. It requires transparency and justification for any discrepancies. Companies can choose between targeted or general increases based on their internal assessment.

If we give the analysis first, would it help prove our approach during an inspection?

Conducting an analysis of remuneration and pay gaps will be a necessary step. This is essential but not sufficient: the company will also have to comply with the other obligations inherent in the directive (duty to provide information, etc.).

Does being in the role for years and receiving NAO give a higher salary than a new hire in the same role?

Yes, seniority is an objective criterion.

If we have different types of directors (CIO, HR, Finance, Communications, etc.), do the positions have the same value?

This is where the value of a job weighting methodology lies: it allows us to look beyond job titles and focus on the impact of these positions on the organisation, using weighted objective criteria. It would be incorrect under the directive to consider two positions to be of equal value simply because they both have the title of director.

For some positions, market pressure increases salaries. How can supply and demand be included in pay gap analysis?

One possible solution is to address labour shortages in certain professions by using ad hoc pay scales (e.g. a specific scale for IT positions with a median salary 10% higher than the median salary on the general scale).

Should we consider actual pay or contractual pay (e.g., for sick leave, part-time employees, etc.)?

Very good point, unfortunately we will have to wait for transposition into national law and implementing decrees, as the directive is not specific on this point.