What Counts as a Compliant Salary Range Under the EU Pay Transparency Directive?

Most employers responded to the EU Pay Transparency Directive by adding a salary line to their job ads. A range that looks something like this: €40,000 to €120,000.

That is almost certainly not compliant. And it is going to cause problems.

The directive became enforceable on 7 June 2026. Its requirement that employers disclose pay information before or during the hiring process is now binding across all 27 EU member states. But the directive is deliberately silent on exactly what a compliant range looks like, which has left most companies guessing.

This piece covers what the rules actually require, what regulators are likely to look at, and how to structure salary disclosure in a way that holds up.

What the directive actually says about salary disclosure

The directive requires employers to provide candidates with information about the initial pay or pay range for the position before the first interview, either in the job advert or in some other way before the interview starts.

Three things to note in that sentence.

First, it says initial pay or pay range. A single number is compliant, technically. A range is also compliant. What is not compliant is nothing, or a vague statement like "competitive salary."

Second, it says before the first interview. Not at offer stage. Not after a screening call. Before any structured interview takes place.

Third, it says the position. This matters because it ties the disclosed range to a specific role and level, not to the company generally or the team broadly.

What the directive does not specify is how wide the range can be. That absence is where most companies are currently taking shelter, and where regulators are going to push back.

Why a wide range is a problem

A €40,000 to €120,000 range for a single role is technically a range. It is also useless to a candidate and almost certainly not what regulators intended.

The purpose of the directive is to give candidates meaningful information about what they can expect to earn, and to allow them to make an informed decision about whether to apply. A range that spans 200 percent of its lower bound gives no meaningful information. Any candidate could be at any point in the range for reasons they cannot assess.

Regulators in France and Belgium, which already have stricter pay transparency requirements, have been clear that ranges must be genuinely reflective of the expected pay for the role. A range constructed to technically comply while revealing nothing is not going to satisfy a regulator looking for good faith compliance.

The practical standard that is emerging is that ranges should span no more than 20 to 30 percent of the midpoint. A role with a midpoint of €70,000 should have a range of roughly €60,000 to €80,000. That reflects real variation based on experience within the level, not the entire possible pay universe for someone doing the job.

The job architecture problem

The reason most companies cannot write clean salary ranges is not that they are unwilling. It is that they do not have the underlying structure to support it.

To post a genuine range for a role, you need to know what level that role sits at, what the pay band for that level is, and where in the band the role typically lands. That requires a job architecture, which most companies of under 200 people have never formally built.

Without a job architecture, the salary range you post is essentially a guess dressed up as a policy. It might be the right number. It might not be. And when a candidate asks, as they now have the right to do, how individual pay levels relate to the posted range, you need to be able to answer with a documented framework, not an improvised justification.

Building a job architecture takes time. For a 50-person company with relatively clean role definitions, four to eight weeks. For a larger company with historical complexity, longer. This is why the 90-day window matters. Starting now puts you ahead of enforcement. Starting after your first complaint does not.

The pay history ban

Alongside salary disclosure, the directive bans employers from asking candidates about their pay history, either directly or through the application form. This is already law in several EU member states, but the directive harmonises it across all 27.

The practical implications are wider than most hiring managers realise. You cannot ask what the candidate currently earns. You cannot ask what they earned in their last role. You cannot use a previous offer as a basis for calibrating the new one. You can only use your own pay framework.

This matters because a significant part of how pay gaps compound over time is through salary history anchoring. New employers use previous salaries as a floor, which carries forward historical underpayment. The directive is deliberately designed to break that chain.

For hiring managers who have been doing this for years, it is a genuine behaviour change, not just a policy update.

The documentation requirement

Even if your job ad has a compliant range and your recruiters are not asking about pay history, the directive still requires you to be able to explain, on request, why any individual employee is paid what they are paid relative to their peers doing equivalent work.

This means the paper trail matters. For every pay decision, whether that is a new hire offer, a promotion increase, or an out-of-cycle adjustment, there needs to be a recorded rationale that links back to your framework. Not a vague note. A specific explanation: this person is placed at the 60th percentile of the band because of X, Y, and Z.

Most companies do not have this documentation for their existing workforce. Building it retroactively, while uncomfortable, is far less uncomfortable than being asked for it in a pay dispute without it.

What to do if your ranges expose a problem

For many companies, the act of mapping roles to levels and bands will surface pay inconsistencies they were not fully aware of. Two people at the same level paid differently, with no documented reason. A female colleague at the bottom of a band while male colleagues at the same level sit at the midpoint.

The instinct is often to delay the mapping exercise to avoid surfacing the problem. That instinct is now counterproductive. Under the directive, the burden is on the employer to prove pay differences are justified. The problem exists whether or not you have mapped it. Mapping it gives you the chance to fix it before enforcement finds it.

Correcting pay equity gaps, with proper documentation of the decision, is a defensible action. Discovering them through a regulatory investigation is not.

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