Pay Transparency: Preparing for the EU Directive 2023/970 | Insights

Pay transparency is set to become a central compliance and strategic issue for employers across Europe.

On 10 May 2023, the European Parliament and the Council approved Directive (EU) 2023/970, which introduces new obligations aimed at strengthening pay transparency and tackling pay discrimination, particularly the gender pay gap. EU Member States must transpose the Directive into national law by 7 June 2026 — with only a few jurisdictions having done so to date.

The Directive applies to all employers, both public and private, regardless of company size, and will significantly affect recruitment processes, internal remuneration structures and employee relations. Among other obligations, employers will be required to:

Provide clear pay information to candidates before employment begins,
Refrain from asking candidates about their current or previous remuneration,
Ensure employees can access information on pay levels for comparable roles,
Address unjustified pay differences, with an enhanced role for employee representatives.

Given the scope and complexity of these changes, ELLINT Next has prepared a dedicated brochure, which we attach here in PDF format, to support companies in understanding how the Pay Transparency Directive is expected to be implemented across different jurisdictions and what practical steps employers should begin considering now.

ELLINT Next is a collaborative forum bringing together current and future partners, attorneys and associates from ELLINT member firms. Through comparative analysis, shared expertise and cross-border perspectives, ELLINT Next aims to provide forward-looking and practical guidance on key developments in employment law.

For 2025/2026, Pay Transparency has been selected as ELLINT Next’s Topic of the Year, reflecting its growing importance for employers operating across borders. This brochure seeks to raise awareness of the upcoming obligations and help businesses prepare for a smoother transition once the Directive becomes part of domestic law.

If you would like to learn more about the Pay Transparency Directive or its impact in a specific jurisdiction, ELLINT members will be pleased to assist you. Please feel free to contact any of our offices using the details provided in the attached brochure.