欧盟薪酬透明度指令的实施——最新立场

March 2026 With less than three months to go until the PayTransparency Directive comes into force, we are startingto see more EU member states take steps to preparefor its implementation. Progress is, however, still slow.This is not a reason for employers not to take action!We would continue to urge affected companies to betaking steps now to comply with the requirements ofthe Directive. It seems that, as was the case with the Whistleblowing Directive, manymember states will be issuing draft legislation late in the day. This makesthings very difficult for employers, but as the minimum requirementsof the Directive are clear, employers should be using these as theframework for their preparations. In the latest version of our “snapshot” guide, we have collaborated withour Global Edge contributors to set out the current state of play in 19 keyEU member states, including an indication of the likely scale of changein different jurisdictions and the potential need for union/works councilconsultation along the way. As the UK is no longer a member of the EU, it will not be required toimplement the Directive. To the extent UK companies have operations incontinental Europe, however, it will, of course, still be relevant. Greatertransparency in pay practices and procedures in EU member states isalso likely to raise the profile of this issue in the UK and potentially triggerdemands from UK staff for similar information. Please note that this guide is intended as a high-level overview only andshould not be regarded as a substitute for legal advice. It sets out theposition as of 16 March 2026. We recommend that you always checkthe latest position with your local labour and employment lawyer. Where“/x” responses are given, they may be dependent on the facts andspecific advice should always be taken. How We Can Help We can support you in relation to all aspects of preparing for implementation of the PayTransparency Directive, as well as your broader pay equity strategy – from reviewing yourcurrent pay structures and practices to identify potential areas of challenge, to supporting with“dry runs” of your gender pay gap reporting in individual EU member states. Our global footprint and extensive experience of delivering global projects for clients means we can provide joined-upsupport to ensure your pay practices and structures align with the requirements of the Directive and any local implementinglegislation across all your affected markets. If you would like to discuss the implications of the Pay Transparency Directive for your business, please speak to your usualcontact at the firm or one of our experts in the first instance. Malgorzata GrzelakPartner, Warsaw Marga CaproniPartner, Brussels Janette Lucas T +48 22 395 5528E malgorzata.grzelak@squirepb.com T +32 2 627 7620E marga.caproni@squirepb.com Partner, LondonT +44 20 7655 1553E janette.lucas@squirepb.com Global Edge Global Edge is an award-winning product that gives instant access to the latest employment law developments in38 countries, direct to a mobile device or desktop. It is an invaluable tool for in-house counsel and HR professionalsin global organisations, providing up-to-date, clear guidance on 30 employment law topics and upcoming legislation.Businesses with operations in continental Europe can keep abreast of developments with the Pay TransparencyDirective by using our “At a Glance” charts. If you need more comprehensive information and support, please visitour Global Edge page or contact us. Key Provisions – Pay Transparency Key Provisions – Pay Gap Reporting Overview Overview Employers must provide job applicants with information about their starting salary(or pay range) for the position applied for. That information must be provided priorto any job interview, e.g. in a job advert. The aim here is to ensure an informed andtransparent discussion, and to minimise the scope for negotiations about pay. •The new pay gap reporting obligations are significantly broader in scope than thosecurrently in place in most, if not all, EU member states. •Large employers will be obliged to report on their gender pay gap – see “WhatInformation Must be Provided?” on page 4 for the specific information that theywill be required to provide and the deadlines for doing so. The accuracy of theinformation provided will have to be confirmed by management, after consultingworkers’ representatives. Employers will be prohibited from asking job applicants about their previous payhistory. The thinking behind this is that candidates should have salary offers based ontheir suitability for the role and not on what they may have been willing to work for atanother employer, since that could have the effect of perpetuating lower salaries forwomen. •Workers’ representatives will have access to the methodologies applied by theemployer and certain information must be provided to the workers and theirrepresentatives. Certain information must also be shared with the rele