While we don’t yet know all the details in most countries, the Directive itself is clear about the fundamentals -- and those fundamentals will require most organizations to make significant changes.
If you’re unfamiliar with the directive or want a refresher on its key elements, I recommend checking out my earlier post where I walk through the basics. Today, I want to focus on what smart companies should be doing now, in May 2025, to get ahead of the curve.
The Basics Are Mandatory. But Many Countries Will Go Further.
Every EU country must implement the core requirements of the Directive, such as salary transparency in job ads, the right of employees to request information on pay levels by gender, and mandatory reporting for companies with over 100 employees.
But member states can also go beyond these basics -- and some already have. A few countries stand out for moving early:
France has drafted amendments that expand reporting obligations to companies with fewer than 100 employees, reinforcing its strong track record on gender equality metrics.
Germany is considering integrating the Directive into its Entgelttransparenzgesetz (Pay Transparency Law), with early drafts pointing toward tighter audit rules for larger firms.
Sweden, already known for robust equality legislation, has indicated it may include intersectional pay gap analysis (e.g., gender + migration background) in national law—a powerful step toward deeper equity.
In most countries, though, we’re still waiting on final legislative texts. That uncertainty is no excuse for inaction. The basics are already known, and companies that wait for final laws to scramble into compliance will likely fall behind—or worse, face legal and reputational risks.
1. Build Your Job Architecture -- Now
A clear and consistent job architecture is absolutely essential. Without it, you can’t track who’s doing what, or compare pay levels in a way that holds up under scrutiny.
You’ll need to define:
- Job families and functions
- Career levels and progression steps
- Criteria for promotion and salary bands
A solid job architecture doesn’t just prepare you for reporting—it gives you clarity and fairness internally, and strengthens your compensation strategy across the board.
2. Set Up Your Data -- Cleanly and Respectfully
Even if you’re not yet doing formal pay audits, the data infrastructure needs to be there. Start building anonymized, accessible datasets with at least the following variables:
- Gender
- Time (tenure) in company
- Occupational group and job level (your job architecture comes in here)
- Hours worked / full-time equivalency
- Time spent on parental or other leave
- All forms of pay: base salary, variable pay, bonuses, overtime, company car value, meal vouchers, stock options, etc.
- If you have it: education/trainings
These are the data that will drive your future compliance.
3. Start Your Internal Analysis
If you have the data, use it. Companies that start internal quantitative pay analyses now will be in a much stronger position in 2026. You’ll know where the problems are (if there are any) and have time to address them proactively.
Waiting to “see what happens” is risky. The Directive includes provisions that shift the burden of proof onto employers in suspected cases of discrimination. If you don’t have your numbers and justifications ready, you’re vulnerable -- not only legally, but also reputationally.
4. Plan for Communication -- Transparency is Coming
Employees will have the right to ask what colleagues of another gender earn in comparable roles. That means your internal communication strategy matters.
What do you want employees to see on your intranet?
Will you offer interactive dashboards with anonymized average pay levels?
How will you prepare managers for tough questions?
What values do you want your communications to reflect?
Starting the conversation now allows you to respond with confidence and integrity, rather than defensiveness and delay.
A Final Word
Preparing for the Pay Transparency Directive isn’t just about compliance. It’s an opportunity to create clarity, trust, and equity in your organization. And the companies who take this seriously now -- who build the structures, gather the data, and communicate proactively -- will not only avoid future headaches. They’ll also position themselves as employers of choice in a world that’s demanding fairness, not just promises.
If you’re ready to take the next steps, I’d love to support you. Whether it’s setting up your datasets, crunching your pay gap numbers, or writing your reports, I’m here to help you navigate this with expertise, warmth, and clarity.
Let’s get started.