The EU Pay Transparency Directive in Practice – 5 Scenarios

1. Pre‑Employment Transparency

Case Study: PortuTek (Portugal)

• Sector: SaaS / Tech
• Size: 180 employees
• Issue: Salary range disclosure + no salary‑history questions

Scenario

Sofia applies for a Product Designer role at PortuTek. Historically, PortuTek allowed hiring managers wide discretion. Salary conversations were vague and negotiable.

Directive Impact

Under the terms of the Directive, PortuTek must:

• Provide the salary range upfront, before interview – in the job ad or at least prior to any discussion.
• Completely remove salary‑history questions from recruiter scripts.
• Ensure gender‑neutral job ads and titles.
• Use objective, gender‑neutral criteria for pay setting.

What it looks like now:

• Original Job Ad Title: Product Design Ninja → Updated Title: Product Designer (Mid‑Level)
• Salary range displayed: €48,000 – €58,000, with documented criteria:
• Education/skills match: Portfolio complexity; Market data; Experience in SaaS design

Sofia later says: “It was refreshing to know the salary range upfront — I didn’t have to guess or worry about being low‑balled.”

Takeaways

Tech companies like PortuTek need to re‑engineer hiring processes: job architecture, range validation, and manager training become essential to avoid drifting outside the published range — which could create legal and cultural risk.

2. Pay Information Requests

Case Study: Mountain Retail Group (Sweden)

• Sector: Retail
• Size: 3,500 employees across 7 EU countries
• Issue: Employees requesting pay information

Scenario

Lukas is a store manager in Vienna. He hears that a male colleague in a similar store might be earning more.

Directive Impact

Under the terms of the Directive, employees can request:

• Their own pay level
• The average pay by gender for comparable roles
• Criteria used for pay & progression (must be gender‑neutral)
• Employers have 2 months to respond.

Mountain Retail Group’s Response System

Before the Directive, Alpine had no centralised pay architecture and relied on local HR managers’ judgment. Now they implement:

• A clear Store Manager job family across all EU markets
• Objective, gender‑neutral criteria (store size, revenue, shrinkage control, performance rating)
• A standard workflow for information requests
• Annual employee reminder: “You have the right to request pay information”

Lukas receives the comparative data showing the average male salary is €47,800 and theaverage female salary is €47,500. The difference is minor and objectively justified based on store turnover.

Takeaways

Large, multi‑country employers must invest in data engineering, job evaluation, and HR system upgrades to track accurate comparable-role data.

3. Gender Pay Gap Reporting

Case Study: HelioPharma (Germany)

• Sector: Pharmaceuticals
• Size: 1,200 employees
• Issue: Annual gender pay gap reporting (250+ employees)

Scenario

Gender Pay Gap Reporting reveals one category — R&D Technicians — shows an unexplained 5.6% gap, which is above the threshold and cannot be objectively justified.

Directive Impact: Joint Pay Assessment (JPA)

Under the Directive, HelioPharma must now:

• Conduct a Joint Pay Assessment with worker representatives
• Analyse all roles, not just the problematic one
• Identify root causes
• Remedy issues within 6 months

Takeaways

This is where organisations feel the “principle to proof” shift: You can no longer rely on narrative or goodwill. The data must stand up to scrutiny.

4. Pay Structures, Progression & Transparency

Case Study: Green Bank (Ireland)

• Sector: Financial Services
• Size: 95 employees in Dublin
• Issue: Transparency of pay policy & criteria

Although <100 employees, and therefore exempt from GPG reporting until 2031, Green Bank still must comply with: Pay range disclosure; Employee information rights; Gender‑neutral criteria No pay secrecy clauses

Scenario

Aisling is a Relationship Manager promoted last year. She feels unclear how her pay rise was calculated.

Directive Impact

Under the Directive, Green Bank must now be able to show documented criteria for pay progression applied consistently across managers. The criteria must be gender-neutral, defensible, and accessible to all workers.

What the Bank Introduces

• Four transparent pay zones (Entry, Developing, Established, Advanced)
• A documented progression framework
• Manager training on defensible pay decisions
• Removal of confidentiality clauses in contracts
• Clear internal “Pay Policy Portal”

Takeaways

Small organisations often lack formal pay architecture — the Directive forces maturity and discipline that many have delayed.

5. Multinational Complexity

Case Study: EuroNom Foods (HQ: UK; operations in Spain, France & Poland).

• Sector: Food Production

Size: 7,500 employees globally; 730 in EU

Issue: UK HQ must comply for EU‑based employees only

Scenario

Marta works in logistics in Spain. She notices that job ads for similar roles in the UK don’t include salary ranges, while Spanish postings now do.

Global Complication

The Directive applies only to EU-located staff, but internal equity pressures mean:

• EU pay transparency pulls UK practices toward greater openness
• Differences in local law (e.g., UK 2025 Employment Rights Act introduction of mandatory narratives) add tension

Action taken

To balance compliance requirements with internal consistency, EuroNom Foods introduced a global pay transparency framework. While maintaining compliance with local legislation, the company established common job families, pay bands and progression criteria across all markets.

The organisation also decided to publish salary ranges for all new roles globally, including in the UK, to reduce confusion and support a more consistent employee experience. HR teams across Spain, France, Poland and the UK received training on pay transparency requirements, employee information rights and the rationale behind pay decisions.

Takeaways

By taking a coordinated approach, EuroNom Foods reduced the risk of employees perceiving unfair differences between countries while retaining the flexibility to meet local legal requirements.

What Next?

The EU Pay Transparency Directive represents more than a new compliance obligation – it signals a shift towards greater accountability, consistency and transparency in how organisations reward their people. If you’re reviewing your pay practices, our specialists can help you assess your readiness and develop a practical implementation plan. Get in touch or book a free consultation call.