Pay transparency: a global guide to the laws and how to get ready

What pay transparency means

Pay transparency means making pay visible to the people it affects: candidates see a range before they apply, employees understand how pay and progression are decided, and regulators or the public see the gender pay gap. Laws now require some or all of these in EU member states as they transpose the directive, a growing number of US states and cities, the UK, Canada, Japan and Australia.

It helps to separate the obligations into four layers, because each jurisdiction picks a different combination.

1. Pre-employment disclosure. A pay range or starting pay in the job advert or before interview, and often a ban on asking for salary history.
2. Pay-setting transparency. Employees can see the criteria used to set pay and progression.
3. Individual right to information. An employee can ask how their pay compares with colleagues doing equal work or work of equal value.
4. Organisational reporting. Gender pay gap figures sent to a regulator or published.

The US has focused mainly on the first layer. The UK has focused on the fourth. The EU directive requires all four, which is why it is the most demanding regime and a sensible design standard for a global employer.

The context is a persistent gap. Eurostat puts the average unadjusted gender pay gap in the EU at 11.1% in 2024 (Eurostat, Gender pay gap statistics). Transparency laws are designed to make the causes of that gap visible to the people who can act on it.

The EU Pay Transparency Directive (EU) 2023/970

The EU Pay Transparency Directive is Directive (EU) 2023/970 of 10 May 2023. It applies to public and private employers, and Article 34 required member states to bring national laws into force by 7 June 2026 (EUR-Lex, Directive (EU) 2023/970).

Two definitions shape everything else. Under Article 3, “pay” includes base salary and any other consideration in cash or in kind, including complementary or variable components. So bonuses, allowances, equity and benefits are in scope, not just base salary. And Article 4 requires pay structures that let you compare the value of different jobs using objective, gender-neutral criteria that include skills, effort, responsibility and working conditions.

Who counts as a comparator

The directive asks about “categories of workers” doing the same work or work of equal value, not job titles. Two roles in different functions can be of equal value. This is the provision that most organisations underestimate, because it cannot be answered from a title list. It needs a job evaluation method.

What the directive does not do

It does not set a maximum range width, and it does not require ranges to be published on job boards; it allows the information to be given before interview “or otherwise”. National laws may go further on both points, which is why the national text matters more than the directive for day-to-day compliance.

EU transposition status as of November 2026

The 7 June 2026 deadline passed with most member states still drafting. Employers are bound by their national transposing law, so obligations are arriving country by country rather than on one EU-wide date.

Trackers maintained by law firms agree on the broad picture. Italy, Lithuania and Malta had transposing laws in force around the deadline, and Greece has since transposed, with its main obligations applying from 1 November 2026. Poland brought in its recruitment transparency rules early, from 24 December 2025, and Belgium has covered parts of its public sector only (Pinsent Masons, EU member state tracker; Lewis Silkin, July 2026).

Several large markets were later. The Netherlands had said its law would take effect on 1 January 2027, France was working towards a 2028 start, Germany’s draft was still pending, and Sweden had put implementation under reconsideration, according to the same Pinsent Masons tracker. Lewis Silkin reports that the European Commission has ruled out any pause or extension.

Because the position changes month to month, treat any tracker as a starting point and check the national gazette or labour ministry for each country where you employ people.

US salary range disclosure laws

The United States has no federal pay range disclosure requirement, but a growing list of states and cities require pay ranges in job postings. Multi-state and remote-first employers generally apply the strictest rule to every US posting rather than manage a patchwork.

Sources: Colorado CDLE INFO #9; California Labor Commissioner; Washington L&I; NYC Commission on Human Rights; New York State DOL; Illinois DOL; Minn. Stat. § 181.173; New Jersey DOL; Jackson Lewis on the Massachusetts law. Other states and cities have passed or are considering similar laws; this table lists only those we verified.

Three rules that catch multi-state employers

• Remote roles. Colorado’s guidance says a remote posting is covered even if it states Colorado applicants will not be accepted, and California’s Labor Commissioner applies its rule if the role may ever be filled in California.
• Open-ended ranges. NYC and Washington guidance both reject ranges like “up to” or “and up”. Publish a real floor and a real ceiling.
• Benefits. Colorado, Washington, Illinois, Minnesota and New Jersey all expect benefits or other compensation to be described, not just base pay.

California also requires private employers with 100 or more employees to submit annual pay data reports to the state, which is a reporting obligation separate from the posting rule. It is worth building both from the same data set.

UK gender pay gap reporting

In Great Britain, employers with 250 or more employees on the snapshot date must publish gender pay gap figures every year, within a year of that date (GOV.UK, gender pay gap reporting). The snapshot date is 31 March for most public authorities and 5 April for private, voluntary and other employers (GOV.UK, preparing your data).

The six required calculations are (GOV.UK, making your calculations):

1. Proportion of men and women in each hourly pay quarter.
2. Mean gender pay gap for hourly pay.
3. Median gender pay gap for hourly pay.
4. Proportion of men and women receiving bonus pay.
5. Mean gender pay gap for bonus pay.
6. Median gender pay gap for bonus pay.

The Employment Rights Act 2025 adds equality action plans for employers with 250 or more employees: at least one action on the gender pay gap and one on supporting employees through the menopause. Government guidance treats publication as voluntary from April 2026, with mandatory publication to follow, subject to secondary legislation (Lewis Silkin, March 2026).

The UK has not adopted the EU directive and has no general requirement to publish ranges in job adverts. UK groups with staff in EU member states will, however, need EU-standard processes for those staff, and it is usually simpler to run one standard.

Canada, Japan, Australia and India

Outside the EU, US and UK, the pattern is similar: either pay ranges in postings, gender pay gap reporting, or both. Here are the rules we could verify.

Canada

British Columbia requires the expected pay or pay range in all publicly advertised job postings, and its pay transparency reports are phased in by size, reaching employers with 50 or more employees in BC by 1 November 2026 (Government of British Columbia). Ontario requires employers with 25 or more employees to include expected compensation in publicly advertised postings made on or after 1 January 2026, with any range no wider than $50,000 a year and an exemption above $200,000 (Ontario Employment Standards guide).

Japan

Japan has required employers with 301 or more regular employees to disclose their gender wage gap since July 2022. An amendment that took effect on 1 April 2026 widens the disclosure duty to smaller employers — reported as those with 101 or more regular employees; confirm the threshold that applies to you with the Ministry of Health, Labour and Welfare (Orrick, July 2026).

Australia

The Workplace Gender Equality Agency collects data from employers with 100 or more employees and publishes employer-level gender pay gaps; its 2026 release covered both private and Commonwealth public sector employers (WGEA, publishing employer gender pay gaps).

India

India’s four labour codes, including the Code on Wages, 2019, came into force on 21 November 2025, with the Code on Wages replacing earlier laws including the equal remuneration framework (Khaitan & Co via Mondaq). We have not identified a national requirement to publish pay ranges in job advertisements. Indian employers with EU, UK or US staff will still feel these rules through those entities, and listed companies should expect investors to ask.

Middle East and the rest of APAC

We have not verified range-disclosure or gap-reporting mandates in the Gulf states or the wider APAC region for this guide. If you employ people there, check local law, and remember that a group-wide policy will often be stricter than local requirements anyway.

Pay transparency readiness checklist

Pay transparency readiness rests on four things: a job architecture that groups work of equal value, salary ranges you can defend, a pay equity analysis you have already acted on, and managers who can explain pay. The job advert is the last step, not the first.

1. Job architecture

The EU directive asks about work of equal value, so you need a consistent way to say which jobs are comparable. That means job families, levels and a documented job evaluation method based on skills, effort, responsibility and working conditions.

• Every employee mapped to one job, one level and one family.
• Level definitions written in gender-neutral language, with soft skills properly weighted.
• A record of how each level was decided, so you can explain it to a worker or an equality body.

2. Salary ranges

A range you publish is a range you have to honour. Build ranges from market data, your compensation philosophy and your actual pay distribution, then test them before they go public. Our salary band calculator is a quick way to model midpoints, spreads and overlaps.

• Decide whether job adverts show the full band or a narrower hiring range, and apply the choice everywhere.
• Find employees paid below minimum or above maximum and set a plan for each.
• Set ranges for variable pay and benefits too, because the directive’s definition of pay includes them.
• For multi-currency groups, set ranges per country, not one converted global figure.

3. Pay equity analysis

Run the analysis before the regulator, a worker or a journalist does. Calculate the gap by category of workers, explain what objective factors account for it, and fix what you cannot explain. Under Article 10, an unexplained gap of 5% or more in any category that is not remedied within six months triggers a joint pay assessment. Our pay equity guide sets out the method.

• Mean and median gaps in base and variable pay, by category of workers.
• A regression or cohort analysis that tests whether legitimate factors explain the gap.
• A remediation budget agreed before the analysis finishes, so findings are fixed rather than debated.

4. Manager communication

Once ranges are visible, every employee can compare themselves to a job advert. Managers need to explain where someone sits in a range and what moves them, in plain language.

• A one-page explanation of how pay and progression are set, accessible to every employee.
• Manager training and a script for the three most common questions: why am I here in the range, what do I need to do to move, and why does the new hire’s range overlap mine.
• A process for written pay information requests with a two-month response time, plus the annual notice of that right.
• Remove pay secrecy clauses from contracts and handbooks.

Running one global standard

The simplest way to comply in many jurisdictions is to design to the EU directive and apply that standard everywhere, then add local extras such as benefits descriptions in US postings or Ontario’s range cap.

A single standard has three advantages. Recruiters follow one process. Employees in different countries get the same answer when they ask how pay is set. And your total rewards story stays consistent across markets, rather than being transparent in one country and opaque in another.

The sequence we would follow for a group employing people across several regions is:

1. Inventory headcount by country, state and entity, and list which laws apply now and in the next 18 months.
2. Build or repair job architecture across the group.
3. Set country-level ranges and close outliers.
4. Run a pay equity analysis on the EU reporting categories, even outside the EU.
5. Publish the pay policy, train managers and update recruiting templates.
6. Set an annual cycle: data cut, analysis, remediation, report, communication.

If your team does not have the capacity to do this alongside a pay review, this is the kind of project our compensation consulting work covers. Terms used in this guide are defined in the glossary.