The EU Pay Transparency Directive's 7 June 2026 transposition deadline came and went with most member states still scrambling. Ignore the legal limbo. The provision that matters for people leaders is quieter: you can no longer ask candidates what they currently earn.
The salary history question was a crutch
For most of my 25 years in enterprise IT, offers were built the same way: current salary, plus 10–15%, rounded to a band. We called it market pricing. It wasn't. It was an import of every underpayment the candidate had ever accepted, permanently relocked into their file. Directive (EU) 2023/970 bans the question outright and requires you to disclose the starting range before the interview. Strip away the crutch and your bands must stand on their own data.
Your bands are about to be audited — by you
This isn't a disclosure exercise. Employers with 100+ workers will report gender pay gaps, with the first reports for the largest companies due June 2027. Where an unjustified gap of 5% or more isn't remedied, the Directive triggers a joint pay assessment with worker representatives. With women in the EU still earning roughly 77% of men's annual pay, plenty of organisations will fail their own audit.
The gap was built one exception at a time
Here's the uncomfortable part. The pay gap rarely comes from policy. It comes from the "hot market" hire, the retention counteroffer, the off-cycle adjustment a manager fought for. Each was defensible in the room. Compiled, they're a pattern — and a liability you now publish.
Don't wait for the first report. Run the audit yourself now: band by band, role by role, by sex. Fix the comp debt before it becomes a headline.