EU Pay Transparency Directive · Wet Loontransparantie
Make your pay decisions defensible — before the law asks you to prove it.
In fast-moving sectors like ICT, finance and consulting, attracting and keeping the right people is critical. Without transparent, defensible pay structures you risk both unequal pay and losing talent to competitors — and, under the new EU rules, real legal and financial exposure.
The Directive, plainly
What the new rules mean for employers
No legal jargon — just what changes, what you need in place, and what happens if you don't.
Employers will have to
- ✓Tell job seekers the starting salary or pay range in the vacancy or before the interview, and stop asking about pay history.
- ✓Give employees, on request, their own pay level and the average pay by sex for workers doing the same or equal-value work.
- ✓Publish the gender pay gap (employers with 100+ employees).
- ✓Run a pay assessment if a gap of 5% or more can't be justified.
Employers need to have
- ✓A market salary-range reference to set pay for a role.
- ✓A job architecture that defines same / equal-value work, so pay can be compared.
- ✓A system ready to answer employee pay-information requests.
- ✓Evidence to meet the reversed burden of proof — the employer must show there was no pay discrimination.
- ✓A pay-gap report each year or every three years, depending on headcount (from 100 FTE).
If the rules aren't met
- ―Fines.
- ―Back pay / compensation to affected workers (up to the last 5 years).
- ―Equality bodies and worker representatives can act on workers' behalf.
- ―A liability that can surface as a cash-out item when the company is sold.
- ―Loss of credibility with staff and the public.
Not sure where you stand? Book a Rapid Pay Transparency Assessment.
Reporting tiers
The bigger you are, the sooner this bites
Obligations phase in by headcount. Whichever tier you're in, the sooner your structures are in order, the less it costs to prove.
Transparency & equal-pay basics apply now. Build clean foundations while it's cheap.
MediumGap-reporting duties phase in for this band. The runway is shorter than it looks.
LargeSquarely in an active reporting band — structure and evidence matter now.
LargestFirst in scope, most scrutiny. This should already be underway.
How we help
Eight ways we make pay defensible
From a fast diagnostic to the full architecture underneath — evaluation, structure, ranges, and the evidence to back it all up.
Rapid Pay Transparency Assessment
A fast, structured diagnostic of where you stand, with a prioritised action list.
02Job evaluation
Objective, gender-neutral evaluation of roles so pay can be fairly compared.
03Job architecture
Job families, levels and career paths that make "equal value" demonstrable.
04Pay ranges
Defensible, market-benchmarked salary ranges that hold up commercially and legally.
05Pay gap analysis
Unadjusted and corrected gap analysis that separates justified from unjustified.
06Compliance reporting
The reports the law requires, aligned with CSRD / ESG reporting.
07Advisory
Senior, tailored guidance, training and an EU Pay Transparency seminar.
08M&A / due-diligence advisory
Pay-gap liability quantified as a net-debt-style risk in a transaction.
Why EqualFrame
A specialist, not a scorekeeper
Plenty of firms can hand you a number. We make that number defensible, and build what needs to sit underneath it.
Independent
Not a Big Four practice, not a data house selling benchmarks. Pay equity is what we do.
Legally anchored
We build toward the evidentiary standard the Directive actually asks for — defensible, not just descriptive.
We design the structures
Job architecture, grades and ranges — the backbone, not just a measurement on top of it.
Senior, hands-on
You work directly with the people who founded the firm, on every engagement.
Ready to see where your organisation stands?
Frequently asked
Questions employers ask us first
The EU Pay Transparency Directive has direct implications for compliance, cost structure and valuation in M&A. Employers must disclose pay differences and justify them objectively; failure can mean salary adjustments, claims and fines, hitting cost structure, EBITDA and net debt. For buyers, pay is no longer just an HR matter — it's part of due diligence. Undocumented gaps or an immature pay structure can lead to price adjustments, extra warranties, or deal risk. This is where our M&A / due-diligence advisory comes in.
The EU Directive's 7 June 2026 transposition deadline has passed, and most member states missed it. The Netherlands is now targeting entry into force around 1 January 2027 via the Wet Loontransparantie, with gender pay gap reporting for employers with 150+ employees starting from calendar year 2027 (first reports due by June 2028) — a year later than the Directive originally prescribed, a delay the European Commission has said it does not support. Belgium missed the deadline at federal level (only partial regional transposition is in force); Luxembourg's draft bill isn't expected before the second half of 2026. See our Benelux obligations & timeline page. (This is a fast-moving legislative process — confirm current status before relying on it for a specific decision.)
All employers, regardless of size, for the transparency and equal-pay basics; gender-pay-gap reporting phases in by headcount from 100 employees upward. See our company-size guide.
Different jobs that are equally demanding when measured by skill, effort, responsibility and working conditions must be paid equally. Deciding which jobs qualify is one of the hardest parts — and where a defensible job architecture matters.
If a gender pay gap of 5% or more in a category of workers can't be justified by objective, gender-neutral factors and isn't corrected within six months, the employer must carry out a joint pay assessment with worker representatives.
Fines, back pay to affected workers (up to five years), action by equality bodies and worker representatives, a possible liability at sale, and reputational damage.
For those who want the detail: the EU Pay Transparency Directive is the legal basis for everything on this page — the Netherlands' Wet Loontransparantie implements it locally.
Download the Directive