Everything you need to know about pay transparency

Can you ask a colleague how much they earn? Does the salary have to appear in a job advert? And does pay transparency mean that everyone with the same job title must receive the same pay?

Pay transparency raises many questions for employees, managers and HR teams alike. We have therefore brought together answers to some of the questions that may arise as pay becomes a more open topic in the workplace.

If you would like some background first, read our in-depth guide to the EU Pay Transparency Directive.

What does pay transparency mean?

Pay transparency means making it clearer how pay is determined and what may explain differences in pay. The EU directive aims to give employees a better opportunity to identify and challenge pay discrimination between women and men.

Are pay transparency and equal pay the same thing?

No. Equal pay is the principle that women and men should receive equal pay for the same work or work of equal value. Pay transparency is a way of examining whether that principle is being upheld. Equal pay is for example already required under Danish law.

Does this mean everyone will be able to see my salary?

No. The new right to pay information concerns your own pay level and average pay levels broken down by gender for relevant categories of employees. It does not generally give access to named colleagues’ payslips.

Can I tell my colleagues how much I earn?

Under the EU Pay Transparency Directive, workers must be free to share information about their own pay when seeking to enforce their right to equal pay. This does not mean you are entitled to know what a particular colleague earns. You can ask them, but it is up to them whether they choose to tell you. The applicable rules in your country determine how the directive is put into practice.

Must employees with the same job title receive the same pay?

Not necessarily. A job title does not always tell the whole story about someone’s duties, qualifications and responsibilities. Differences in pay must not be based on gender, however, and assessments must be based on relevant factors. Two project managers, for example, may have different areas of responsibility. It is therefore useful to look at the work itself when explaining differences in pay.

Can different jobs be considered work of equal value?

Yes. Comparisons are not limited to identical roles. Different jobs can have equal value even if the duties differ. This requires an overall assessment of relevant qualifications and other aspects of the work. It is therefore a good idea for your organisation to establish a clear structure or policy for classifying jobs into categories.

Must the salary appear in every job advert?

The EU directive requires applicants to receive information about the starting salary or pay range, but that information does not necessarily have to appear in the job advert itself. It can also be provided in another way so that applicants can enter pay negotiations on an informed basis. For employers, including a pay range in the advert can be a practical way to align expectations early in the recruitment process.

Can an employer ask what I earned in my previous job?

Under the directive, employers must not ask applicants about their pay history. Instead, an interview discussion can focus on the salary range for the role, the candidate’s qualifications and the expectations of the job.

Can I still negotiate my pay?

Yes. Pay transparency does not put an end to individual pay negotiations. Pay decisions must, however, comply with the principle of equal pay, and the criteria must be objective and gender-neutral. As an employee, you can prepare for the conversation by gathering specific examples of your duties, achievements and any changes to your responsibilities.

How quickly must an employer respond to a request for pay information?

The EU Pay Transparency Directive states that employees must receive a written response within two months of making a request. Your organisation should therefore have a clear procedure for who receives requests, gathers the information and sends the response.

Does pay transparency apply only to large companies?

No. Under the EU Pay Transparency Directive, requirements such as providing applicants with pay information and responding to employees’ requests for pay information apply to employers of all sizes. Pay reporting requirements generally apply to employers with at least 100 workers, with deadlines that vary by company size. Individual countries may introduce additional requirements, so check the national rules that apply to your organisation.

When does the EU Pay Transparency Directive take effect?

The EU Pay Transparency Directive required member states to bring it into national law by 7 June 2026. The rules that apply to your organisation, and the dates you need to meet, depend on the legislation in each country where you operate. Check the relevant national rules when planning your next steps.

Does a pay gap of 5 per cent automatically mean that a company is breaking the rules?

No. The EU draft legislation describes a joint pay assessment when all three of the following conditions are met:

• Reporting shows a difference of at least 5 per cent between the average pay levels of women and men in a category of employees.
• There is no objective, gender-neutral justification for the difference.
• The difference has not been remedied within six months of reporting.

What should I do if I feel my pay is unfair?

Start by asking for an explanation of how your pay was determined. Ask specifically which criteria apply to your role and how your duties and qualifications are taken into account. Gather relevant information, such as payslips, your job description and any agreements concerning responsibilities or allowances. If you still have concerns after receiving an explanation, you can raise the matter with your employee representative or trade union.

How do we compare the pay of part-time and full-time employees?

Monthly pay alone can give a misleading picture when employees work different numbers of hours. A practical starting point is to compare pay on a consistent basis, such as hourly pay, while also examining its individual components. Otherwise, you risk confusing differences in working hours with differences in rates of pay.

What does time tracking have to do with pay transparency?

Time tracking can help explain the relationship between working hours and the pay an employee receives. This is relevant, for example, when overtime or evening and weekend shifts attract additional pay. If two employees receive different amounts, information about their hours and allowances can help establish why. A pay comparison also requires relevant information from HR and payroll systems.

Can a digital system ensure that we comply with the rules?

A system can help bring data together, calculate differences and make documentation easier to manage. Your organisation must still decide which jobs can be compared, which pay criteria are relevant and how to address any issues. Choose digital tools based on the specific tasks you need to carry out, and check whether your existing systems can provide the necessary information.

Where should we start as a company?

Start with three questions:

• Can we explain our pay criteria?
• Can we compare relevant groups of employees?
• Can we find the data we need?

The answers will show where to begin. You may need updated job descriptions, consistent principles for allowances or a better link between HR, working hours and payroll. Then agree who is responsible for the data, employee enquiries and follow-up. This turns pay transparency into a practical task that you can address systematically in your day-to-day work.

If you would like professional help and advice on managing the requirements of the Pay Transparency Directive, please contact us. We specialise in HR controlling, working time rules and workforce management. Give us a call to find out how our systems can help you.