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White Paper

EU Pay Transparency Directive – Transposing into national law

By Eva Jesmiatka , Margrét Bjarnadóttir , Gordon Bartlett , Florian Frank , Tamsin Sridhara and Valentina Rocchi | June 5, 2024

The EU Pay Transparency Directive requires each Member State to introduce legislation by 2026, and how they do this will be critical to the impact it will have on pay equity. Our whitepaper sets out that ambition to maximize its impact on fair pay in national laws.
Compensation Strategy & Design|Employee Experience|Health and Benefits|Inclusion-and-Diversity|Pay Equity and Pay Transparency|Ukupne nagrade |Benessere integrato
Pay Transparency Legislation

The European Union (EU) Pay Transparency Directive will have a lasting impact on pay equity and transparency in Europe. We have arrived at the point where individual Member States need to transpose the EU Pay Transparency Directive into national law.

There is therefore a unique window of opportunity to align national-level regulations with the goal of maximizing the impact of the EU Pay Transparency Directive on fair pay, to enable comparison across Member States and to root requirements in practical realities to minimize the regulatory burden.

About our whitepaper

In this whitepaper, WTW and our co-authors from PayAnalytics and A&O Shearman, point out numerous considerations that any national regulation should address and provide recommendations rooted in both fairness and practicality.

Our recommendations include commentary across the following:

  • Definition of an employer
  • Workers in scope: definition of employees and employment relationships
  • Definition of categories of workers
  • Definition of pay, pay elements considered and the basis of valuation
  • What is meant by pay period for gross annual pay and for average pay levels
  • How hourly pay is calculated
  • The minimum sample size for categories of workers
  • What is classified as objective gender-neutral criteria

How do organizations benefit?

Organizations will benefit from this whitepaper as they can see how the interpretation of the EU Pay Transparency Directive and its subsequent application in national law may impact future reporting requirements and remediation of pay gaps.

Download this whitepaper to find out our specific guidance and expert recommendations for transposing this important directive into national law.

Complete the form on the right, or below on a mobile device.


Europe Pay Equity Lead

Senior Director, Head of Work and Rewards Germany/Austria

Global Pay Equity Lead
email Email

Senior Director, Integrated & Global Solutions
email Email

Co-author contacts

Margrét Bjarnadóttir
Associate Professor of Management Science and Statistics, University of Maryland, Founder of PayAnalytics

Gordon Bartlett
Senior Associate – Employment, A&O Shearman

Find out how ready you are for the EU Pay Transparency Directive

Contact us for details of our EU Pay Transparency Readiness Check and understand where to start, how to develop your roadmap for change, and become confident in pay equity to be ready for greater pay transparency.

Contact us