The European directive on pay transparency is entering a decisive phase. As 2026 approaches, companies must now prepare to produce reliable indicators, explain their pay gaps and demonstrate the objectivity of their practices. During our latest webinar, Pedro Montoya, co-founder of OptimaHR, shared a clear and operational perspective on the challenges ahead, along with a demonstration of the tooling required to effectively manage this transition.
In this third episode dedicated to pay transparency, we revisited the fundamentals: seven legal indicators, including the now well-known seventh indicator relating to worker categories, which will be at the heart of future obligations.
While the first six indicators are relatively classic (average and median gaps, analysis of variable pay, quartile distribution…), the seventh represents a major shift. It requires organisations to group employees into homogeneous categories defined according to objective and non-sexist criteria. These categories will then be used as the basis for a detailed analysis of unexplained pay gaps.
As Pedro Montoya reminded us, “without the right tools, it will be very difficult to meet the requirements of pay transparency”. The exercise demands reliable, consolidated, traceable and statistically exploitable data.
This is the first major challenge identified. Today, the criteria remain somewhat unclear, but four dimensions are already confirmed: the skills required, the level of effort, the level of responsibility and working conditions. Additional dimensions may emerge, such as non-technical skills.
Defining these categories is a key organisational task, as they must be:
According to Pedro Montoya, “at least ten people per category, including three men and three women, will likely be necessary to ensure valid statistical analysis and comply with GDPR”.
Once categories are defined, the next challenge is identifying the objective criteria that actually shape compensation in practice. This means moving beyond HR intuition to rely on factual data.
Optima HR provides a statistical engine capable of:
The regulatory objective is clear: the unexplained gender pay gap must not exceed 5 % within each worker category. Companies will therefore need to justify why a gap exists and based on which objective criteria.
Statistical modelling is only as reliable as the underlying data. This is where many organisational challenges emerge:
Pedro Montoya emphasises this point: “many gaps originate at entry into the organisation”. A poorly negotiated hiring salary can create long-term disparities that become problematic once employees gain the right to request transparency.
Organisations must therefore review their HR processes, document decisions and ensure that all relevant information is captured in their HRIS. Technical integrations—especially with SuccessFactors—are becoming critical to ensure data quality.
OptimaHR can detect employees who are significantly above or below their “theoretical” salary calculated by the model. These cases require human assessment: some gaps are legitimate (rare expertise, strategic hire, market constraints), while others reveal issues (underpaid recruitment, lack of progression, managerial bias).
Documenting these situations is essential. From 2026 onward, each employee will have the right to request information about their pay relative to their peers. Employers must be prepared to justify any differences.
Once gaps are identified, companies must estimate the budget needed to bring unexplained gaps below the 5 % threshold for each worker category.
The amounts can be substantial. Optima RH’s solution helps organisations:
The goal is not to correct everything overnight, but to implement a clear, documented and progressive plan.
Three priorities emerged from this webinar:
The pay transparency directive will significantly transform compensation practices. Organisations that begin preparing now will gain a strategic advantage: strengthened compliance, improved internal fairness, increased employee trust and enhanced employer brand attractiveness.
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.
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.
Pedro Montoya is co-founder of the OptimaHR solution and product manager of the salary transparency module within that solution. His in-depth knowledge of the strategic and operational issues related to payroll and data analysis makes it possible to simplify the management and simulation of payroll headcount and optimise your salary transparency policy.
No, it applies to both the private and public sectors in the 27 countries of the European Union.
Yes, seniority is recognised as an objective criterion in the analysis of pay gaps.
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.
No. The directive requires a company-specific analytical job evaluation system, in addition to the collective agreement.
Risks include individual or collective litigation, financial penalties, loss of employee confidence, and difficulties in recruiting or retaining talent.
Not necessarily. It requires transparency and justification for any discrepancies. Companies can choose between targeted or general increases based on their internal assessment.
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.).
Yes, seniority is an objective criterion.
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.
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).
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.