《薪酬透明度指令》将于2026年6月7日生效——你们的准备工作进展如何？

How are your preparations going? With less than a week to go until the Pay Transparency Directive comesinto force, many businesses with operations in continental Europe arecontinuing to take steps to ensure compliance despite the fact that the Member state implementation – The latest position EU member states are required to introduce local legislation to implement the Directive.Only a few countries are on track to do this, and a number of jurisdictions have alreadyindicated that they will not be introducing their implementing legislation in time for 7 June Having previously made clear that it expects all member states to implement the Directiveby the deadline and that enforcement action will follow where necessary, the EuropeanCommission has since reiterated that it has no plans to “stop the clock” on implementation The Pay Transparency Directive requires all employers (regardless of headcount) toprovide job applicants and workers with greater information about pay (including benefits)to ensure more informed and transparent discussions about pay. It also requires largeremployers (100+ workers) to report regularly on their gender pay gap – with the first roundof reporting due to be made by 7 June 2027, using 2026 data – and to conduct a joint payassessment with workers’ representatives where there is an unexplained gender pay gap The lack of local implementing legislation does of course make things more difficult foremployers but, as we have highlighted before, this should not act as a barrier to employerstaking action. As the minimum requirements in the Directive are clear, employers shouldbe using these as the framework for their preparations, especially as many member states As the UK is no longer a member of the EU, it is not required to implement the Directive. Tothe extent that UK companies have operations in continental Europe, it will, of course, stillbe relevant. Greater transparency in pay practices and procedures in EU member states is How we can help What should global companies already be doing? We are currently working with a number of global companies to ensure their pay practicesand structures are compliant with the minimum requirements of the Directive and likelylocal legislative requirements. Our global footprint and extensive experience of deliveringglobal projects for clients means we can support you in relation to all aspects of preparing We appreciate that businesses are at different stages in terms of their preparations for Collating the data–Do you have all your relevant pay data in one place so thatyou can easily interrogate and extract what you need going forward? In our Reviewing and assessing your current pay and benefit arrangements– Thiswill enable you to determine the extent of compliance with the new obligationsand any potential areas of challenge. Potentially tricky issues include considering Janette LucasPartner, LondonT +44 20 7655 1553janette.lucas@squirepb.com Communicating with relevant stakeholders–What steps have you taken withyourworker representative bodies to prepare for implementation, e.g. any relatedunion/works council consultation requirements? How are you communicating with Marga CaproniPartner, BrusselsT +32 2 627 7620marga.caproni@squirepb.com Don’t forget training–Have you upskilledyour HR team and your managers, asthey will play an important role in ensuring compliance with these newobligations? The Directive requires ongoing compliance and so is a long-term Małgorzata Grzelak Partner, WarsawT +48 22 395 5528malgorzata.grzelak@squirepb.com Monitoring local developments–Continue to monitor what is happening inrelevant individual member states and make changes, as necessary, to reflect