The first pay-transparency request will be a payroll question.

The first request will probably arrive by email. An engineer asks, as the directive allows, for her pay level and the average pay of colleagues doing work of equal value, broken down by sex. HR has two months to answer. It sounds like a reporting task. It becomes a payroll question the moment someone has to decide what counts as pay: base salary only, or the shift allowance, the bonus and the company car too. The directive's definition covers all of it, in cash or in kind.

What the directive asks for

Directive (EU) 2023/970 gives every worker, whatever the size of the employer, the right to request their individual pay level and the average pay levels, broken down by sex, for workers doing the same work or work of equal value, with an answer due within two months. Employers with 250 or more workers must report on their gender pay gap every year from June 2027; those with 150 to 249 every three years from the same date; those with 100 to 149 every three years from June 2031.

When a report shows a gap of at least 5% in any category of workers that the employer cannot justify on objective, gender-neutral criteria, and has not remedied within six months, a joint pay assessment with workers' representatives becomes mandatory.

Where transposition stands

The deadline was 7 June 2026. Italy, Slovakia, Lithuania and Malta met it. Greece and Estonia adopted laws shortly after, with Greece's main obligations starting in November 2026. As of the end of September 2026, Spain and Portugal had published drafts in August, Hungary planned adoption in October, the Netherlands scheduled its plenary debate for January 2027, Denmark and France were aiming at 1 January 2027, Sweden had paused, Belgium had asked for six more months, and Germany had no bill. A November 2025 survey of more than 400 European employers found only 24% describing themselves as very prepared.

Waiting for national law is a risk of its own. Once a directive's deadline has passed, national courts read existing law in its light, and the countries that have transposed, Slovakia among them with fines of up to 100,000 euros and compliant pay structures required by 31 July 2026, show what the others will look like.

Where it breaks: the HRIS and payroll

Every obligation needs the same foundation: workers grouped into categories of equal work or work of equal value, with pay recorded consistently enough to compare. In practice that foundation fails in predictable places.

1. Job codes with no grade, and grades with no pay range.
2. The same role coded differently across sites, often a legacy of an acquisition.
3. Pay components recorded inconsistently: a bonus in one country, an allowance in another, a one-off payment in a free-text field.
4. Pay in the HR system that does not match payroll, and hours that do not match contracts. The gap is measured on hourly earnings, so part-time hours and overtime have to be right.
5. Effective-dated history that cannot reconstruct what someone was paid on a given date, because corrections overwrote the record instead of adding a new one.
6. Sex recorded in a way the reporting cannot use, or missing for part of the population.

Equal value is a judgement, so record it like one

Grouping roles into work of equal value means weighing skills, effort, responsibility and working conditions, the criteria the directive names. It is a judgement, and it will be challenged. Treat it like any decision that has to stand up later: who made it, on which criteria, when, and on what data. An HR system that can answer those four questions has done most of the work.

Where an assistant helps, and where it must not

An assistant is useful for the tedious, high-volume parts: finding job codes with no range, reconciling HR pay against payroll, flagging categories where the gap crosses 5%, and drafting the answer to an individual request from current records, with every figure traced to its source. It must not decide which roles are of equal value, or explain a gap away. Those decisions belong to people who can be asked about them later.

A first ninety days

1. Weeks 1 to 3: inventory job codes, grades and ranges, and list every role without one. Reconcile one month of HR pay against payroll.
2. Weeks 4 to 6: agree the criteria for work of equal value with HR, legal and employee representatives. Where a works council has co-determination rights, start there; it sets the pace for everything after.
3. Weeks 7 to 9: run a dry-run pay gap by category, and find the gaps you cannot yet explain.
4. Weeks 10 to 13: write the answer to an individual request as a template, and test it on real cases.