Pay transparency compliance checklist: 12 steps every HR team must take in 2026
Most HR teams know the EU Pay Transparency Directive applies to them, but few are as ready as…
Pay transparency in practice: what HR leaders need to do now
The EU Pay Transparency Directive entered into force on 7th June 2026. Since then, HR teams across Europe have been asking the same question: what does this mean for us? What needs to change, and where do we start?
To answer that, Assessio’s Head of Customer Success Andréa Claviez-Homberg sat down with Vicky Peakman, Founder and Director of Fair Pay Partners, for a conversation about what the directive demands of HR teams in practice. Watch the webinar on demand →
Why most pay structures fail the directive’s test
Many HR teams assume the main challenge of the directive is building a compensation framework. But most organisations already have structures in place. The harder task is questioning whether those structures can do what the directive specifically requires: demonstrate that pay reflects the value of work, not the identity of the person doing it.
Vicky was clear on where the gaps most commonly appear. Some structures are built around jobs or job families rather than equal-value groupings. Others have ranges that are too narrow or too broad. But the most common issue isn’t the framework at all. “It’s not about the structure itself — it’s about where employees are in it. If you can’t explain why one person’s up here and one person’s down here, that’s the problem.”
Pay transparency compliance: what to do before national guidance lands
Most EU member states missed the 7th June 2026 transposition deadline. For HR teams waiting for national guidance, Vicky’s advice was to get ahead. The directive is the minimum standard. Whatever national law adds will extend transparency further. That means the foundation work is safe to do now: sorting equal-value job groupings, building pay structures around those groups, and documenting the criteria for where each employee sits within them.
For a full breakdown of the directive’s obligations, see our complete guide to the EU Pay Transparency Directive → and the 12-point compliance checklist →
Preparing managers for pay transparency conversations
The directive’s transparency provisions are designed to reduce the power imbalance in pay conversations, ensuring employees have information rather than going in blind. But that only works if managers are equipped to respond well.
Vicky named the most common mistake clearly: “The main failure is not giving managers enough information. Just giving them the numbers and a vague ‘we pay for skills, experience and performance, while taking into account budget’ is not enough. They need to understand how the numbers came to be and why.” Managers need to know not just what an employee is paid, but how they sit relative to their peers, and how to demonstrate that the criteria have been applied consistently. Some will struggle initially but managers who must explain pay decisions will go on to make better choices.
Pay transparency as a competitive advantage
Some organisations aren’t waiting for transparency to be made mandatory. Vicky cited Novo Nordisk as the example worth watching. They implemented a self-service portal where employees can see their own pay, their range, variable benefit targets, and the levels above them, across all countries. “What they are saying is: we are confident in how we pay, we don’t have anything to hide, and we want you to know that you can trust us.” They’re using transparency as a sales tool for candidates and a retention tool for employees.
Three pay transparency priorities for HR leaders
Vicky closed with three takeaways she’d want every HR leader to act on now.
1. Write your pay philosophy down. Then say it out loud. “If you say your pay philosophy out loud and you’re like, ‘Oh, that doesn’t sound good’ — then you can change it now. Now’s the time.” If it sounds right, share it with your employees.
2. Get your equal-value job groupings sorted. Understand how you’re categorising roles of equal value and make sure pay structures map to those groups. This is the foundational technical work the directive is built on.
3. Trust your expertise. Compensation professionals have been keeping their methodology hidden for too long. The directive is an opportunity to show the good work they do. “Your employees should be happier, you should be getting better candidates, and pay gaps will get smaller. That’s what you’re looking for.”
