news & insights
back to all news
Website Covers 13

Mobilising stakeholders to avoid being subjected to pay transparency policies

Access the replay (FR)
Salary transparency 2026

Make salary transparency part of your corporate culture

Since 2010, Arago has been supporting European companies in transforming their HR and finance functions. As the 2026 deadline approaches, pay transparency is becoming a major priority for all organisations. The new European law introduces both obligations and opportunities: it is a chance to strengthen your compensation strategy, improve internal trust and enhance your employer brand.

This article summarises the key insights from our webinar with Xavier Le Mondement, compensation expert and specialist in pay transparency. It outlines the regulatory impacts and explains how to mobilise your stakeholders to successfully manage this cultural shift.

Understanding the purpose of the new pay transparency law

The European directive coming into effect in 2026 introduces a new framework around salary and transparency. Contrary to popular misconceptions, the law does not require organisations to publish all salaries or homogenise all compensation levels. Instead, it aims to improve fairness, reduce unjustified pay gaps and provide employees with clearer access to information.

Key obligations include:

  • providing employees with the average salary for their job category,
  • prohibiting the use of salary history in recruitment,
  • defining and communicating objective criteria for salary decisions,
  • strengthening transparency within compensation processes.

Beyond compliance, this directive represents a real cultural transformation that impacts HR teams, managers, employee representatives, leadership and employees themselves.

Conducting an initial assessment: the essential first step

Before taking action, organisations must understand their starting point. Arago uses a structured four-step approach:

  1. Audit – analyse current practices, salary data, tools and local specificities.
  2. Mapping – identify key populations, maturity levels and risk areas.
  3. Process review – assess how compensation decisions are made in reality.
  4. Interviews – collect perceptions, informal practices, concerns and expectations.

This approach determines whether an organisation already has a solid foundation or needs to build its compensation transparency framework almost from scratch.

Engaging stakeholders: the key to success

Success depends on more than technical compliance. Pay transparency requires a collective shift in mindset and involvement from all stakeholders:

  • Leadership, to secure support and resources,
  • Employee representatives, to ensure a constructive social dialogue,
  • Managers, who will face most salary-related questions,
  • HR teams, who ensure coherence, compliance and implementation.

One powerful method is to create internal personas to tailor communication and support. The concerns of a junior employee differ from those of a senior employee or a manager responsible for a large team.

Creating a sense of urgency ahead of 2026

With the law coming into force in mid-2026, organisations must build a sense of urgency. Otherwise, daily priorities may delay preparations and create risk. Arago helps structure a clear roadmap so each stakeholder understands what is expected and takes action early.

Communicating now is essential to avoid being overwhelmed when employee requests for salary information increase. Given the legal response times, delayed preparation could quickly become a bottleneck.

Training HR teams, managers and recruiters

Pay transparency ultimately relies on the ability of people—not systems—to communicate clearly and confidently. Training is therefore critical.

Training HR teams

HR departments must understand:

  • the legal requirements,
  • data protection and GDPR constraints,
  • the operational impacts of the law,
  • how to manage sensitive or complex cases.

Training managers

Managers need support to:

  • answer questions about salary with confidence,
  • explain compensation criteria,
  • manage difficult conversations,
  • guide employees through this new transparency culture.

Training recruiters

Recruitment teams must adapt to:

  • the prohibition of salary history questions,
  • the obligation to share salary ranges,
  • greater alignment between employer brand messaging and actual practices.

Managing obstacles and embedding the change over time

Implementing pay transparency often triggers concerns or resistance. These reactions are normal and closely linked to fear of losing control or the complexity of past decisions. Arago recommends several approaches:

  • conduct a pre-mortem to identify potential risks early,
  • prioritise actions based on impact and urgency,
  • test approaches with pilot groups,
  • organise regular feedback loops,
  • document all processes to ensure consistency and longevity.

Pay transparency is not a one-off project. It must become an ongoing practice integrated into recruitment, annual reviews, HR communication and compensation governance.

Turning pay transparency into a competitive advantage

Rather than a constraint, the new transparency law can become a real driver of performance. It strengthens internal fairness, improves the employee experience and supports a more credible and attractive employer brand.

Organisations that begin preparing now will better manage risks, retain talent and differentiate themselves in the market.

Arago supports companies at every step of this transformation by aligning strategy, tools and change management to make pay transparency a long-term positive force.

Would you like to find out more?

Make an appointment with our experts to discuss your pay transparency policy, tailored to your specific context!

You can also check out the rest of our webserie on pay transparency.

The key points

Discover the highlights of this episode in this video.

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 provide the analysis initially, could this help us to prove our approach in the event of 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 having been in the position for years and being a beneficiary of the NAO entitle one to a higher salary compared to a new hire in a similar position?

Yes, seniority is an objective criterion.

If we have several types of directors (CIO, HR Director, Finance Director, Communications Director, etc.), do the positions retain 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 certain positions, pressure on the labour market is leading to higher salaries. How can this reality of supply and demand be incorporated into the analysis of pay gaps?

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 take into account the remuneration actually paid or the contractual remuneration (e.g. how to treat employees on sick leave with daily allowances, 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.