Pay transparency across the EU: implementation of the Directive in 14 Member States

With the support of Forvis Mazars specialists from across Europe, we have conducted a comparative analysis showing that the implementation of the Directive is at different stages of maturity across Member States. However, the direction is clear: a transition towards pay systems that are more transparent, better documented and auditable.

The Directive introduces requirements that apply throughout the entire employment relationship, from recruitment to reporting and monitoring mechanisms. Companies will therefore be required to communicate salary ranges already at the recruitment stage, establish pay structures based on objective and gender-neutral criteria and ensure employees have access to information regarding pay levels and pay progression.

In addition, organisations will be required to implement regular gender pay gap reporting mechanisms and, where pay disparities of at least 5% are identified and cannot be objectively justified, to take corrective action within a specified timeframe.

Across the European Union, the gender pay gap decreased to approximately 11.1% in 2024; however, the pace of progress remains below expectations. In this context, the new legislative framework aims to accelerate progress by increasing transparency and strengthening organisational accountability.

Member States are adopting different approaches to the transposition process. Some, such as Slovakia, have already completed the full implementation of the Directive, while others are proposing complex and detailed models featuring extensive monitoring and enforcement mechanisms. At the same time, certain jurisdictions are relying on adjustments to existing legal frameworks or on the role of social dialogue in implementing the new requirements.

Romania falls into the category of Member States pursuing a comprehensive transposition approach, applicable to both the public and private sectors, with clear obligations regarding transparency in recruitment, gender pay gap reporting and employees’ right to access pay-related information. However, the relatively low gender pay gap - estimated at approximately 3.7% - should be interpreted in light of the specific structural characteristics of the labour market.

“The Directive is not merely a compliance exercise; it represents a fundamental shift in how organisations design and justify their pay policies. In practice, companies will be required to demonstrate, in a consistent and well-documented manner, how pay is determined and to eliminate any differences that cannot be explained by objective criteria”, said Florina Ilie, Senior Manager, HR & ESG Advisory, Forvis Mazars in România. “At the same time, we are at a key moment locally - in the coming days, we expect the publication of the final version of the Directive’s transposition into Romanian legislation, which will provide a clear framework for implementing the new requirements and accelerate organisations’ preparation efforts.”

The analysis highlights that the impact of the Directive will not depend solely on the formal adoption of legislation, but also on companies’ ability to integrate the new requirements into effective internal processes. In the absence of clear job evaluation systems and objective pay-setting criteria, transparency risks becoming a purely formal exercise, with limited impact on achieving genuine pay equity.

In the medium and long term, increased levels of pay transparency have the potential to generate significant benefits for companies, including stronger alignment between management and HR functions, clearer communication with employees and more consistent and predictable compensation structures.

The full analysis of the implementation status of Directive (EU) 2023/970 across the Member States of the European Union is available HERE.

###

Press contacts

Emilia Popa, Head of Marketing, Communication, and Business Development, Forvis Mazars in CEE & in Romania
emilia.popa@forvismazars.com  / +4 0741 111 042

Mădălina Lazăr, PR & Corporate Communication Manager, Forvis Mazars in Romania
madalina.lazar@forvismazars.com  / +4 0763 385 622