The EU Pay Transparency Directive: what IT companies need to do before June 2026

The EU Pay Transparency Directive (Directive (EU) 2023/970) is EU-wide law aimed at closing the gender pay gap through transparency and enforcement. It entered into force in June 2023, and EU member states must transpose it into national law by 7 June 2026. The exact rules — and penalties — are set by each country's implementing law, so the details vary by where your people are employed.

A common misconception is that this is “only for big companies.” The gender-pay-gap reporting obligations are phased by headcount, but the core transparency duties — pay ranges for candidates, the ban on asking salary history, the right to information, and pay based on gender-neutral criteria — apply to employers of all sizes. For a growing IT team, the question isn't if this touches you, it's how ready your pay structure is when it does.

• Pay transparency for candidates. Employers must give applicants the pay level or range for a role — in the job posting or before the interview — and may no longer ask candidates about their pay history.
• Right to information. Employees can 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.
• Gender-neutral criteria. Pay and progression must rest on objective, gender-neutral criteria — which in practice means documented job levelling and pay bands.
• Gender-pay-gap reporting (phased by size). Broadly: employers with 250+ employees report annually (first reports expected around 7 June 2027); 150–249 report every three years (from ~2027); and 100–149 report every three years (from ~2031). Under 100 employees, reporting is not mandatory under the directive — but the duties above still apply.
• Joint pay assessment. Where reporting reveals a gender pay gap above 5% in a category of workers that isn't justified by objective criteria and isn't fixed within six months, the employer must carry out a joint pay assessment with worker representatives.

Most teams in this range sit below the 100-employee reporting threshold today, so mandatory gap reporting likely isn't your immediate concern. But the parts that do apply regardless of size — salary ranges in job posts, no salary-history questions, the right-to-information response, and gender-neutral pay criteria — land now. And outsourcing/product teams grow quickly; it is far cheaper to build objective bands and levelling before you cross a threshold than to retrofit them under a reporting deadline.

• Define documented salary bands per role and seniority level.
• Base pay and promotions on objective, gender-neutral criteria — a written career ladder, not gut feel.
• Put a salary range in every job posting.
• Remove salary-history questions from your hiring process.
• Keep clean, role-linked compensation records so you can answer a right-to-information request and, later, run a pay-gap analysis.

Helia HR gives you the structure and records the directive rewards:

• Career ladders with objective grade criteria — gender-neutral levelling you can point to for pay and promotion decisions.
• Salary bands per grade and compensation records, with every access to pay data HR-only and written to an audit log.
• Structured recruitment — consistent job postings you can attach a pay range to.

Helia HR provides tooling and records to help you prepare; it is not legal advice and does not, by itself, make you compliant. How the rules apply to you depends on your national implementing law — confirm the specifics with qualified counsel in each country where you employ people.