The practical guide to European & US pay transparency for talent acquisition leaders
I Executive Summary: Getting ready for pay transparency
The way companies handle pay is changing fast. New laws across Europe and in many US states mean businesses need to be open about salaries. For Talent Acquisition (TA) leaders, this isn’t just a legal hurdle; it’s a chance to attract better candidates and make hiring smoother.
This guide helps TA leaders understand these new rules. We’ll cover what’s required in different places, the good and bad sides of these changes, and practical steps to make your hiring process compliant and competitive. By being open about pay, your company can look better to job seekers, hire more efficiently, and build a fairer workplace. This gives you a real edge in finding great people.
Important note on scope: This whitepaper focuses specifically on the recruitment-related aspects of pay transparency, particularly the requirements affecting job postings, candidate interactions, and the hiring process. It does not delve into other significant parts of the EU Pay Transparency Directive, such as mandatory gender pay gap reporting for existing employees, employees’ right to request pay information, or the rules around joint pay assessments and shifting the burden of proof in equal pay claims. These broader HR and legal compliance topics are crucial but fall outside the direct scope of talent acquisition and are often covered in more detail in resources for HR and legal teams.
II The European lay of the land: A mix of cultures and rules
Pay transparency in Europe is a patchwork. Some countries have a long history of openness, while others are just starting to adapt, mainly because of the new EU Directive.
A. The EU Pay Transparency Directive: The big change for member states
The EU Pay Transparency Directive, passed in June 2023, is a major step to close the gender pay gap. It focuses on fair pay for similar work and making pay structures clear.
What TA teams in the EU must do (before hiring):
Show salary ranges: You must include the salary range for a job in the advertisement or tell candidates before the first interview.
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No salary history questions: You cannot ask job applicants about their past salaries.
Deadline: EU countries have until June 7, 2026 to turn this directive into their own national laws. While the main rules are the same, each country might add its own details.
A look at key EU countries:
Germany: Already has a Pay Transparency Act (Entgelttransparenzgesetz). The culture is traditionally private about pay, but the law is shifting this. Germany will update its law to fully match the EU Directive by June 2026, adding more rules for pre-hire transparency.
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France: Has tools for reporting gender pay gaps (Index de l’égalité professionnelle). The culture is becoming more open, and the EU Directive will push this further. Expect stronger rules for showing salaries in job ads by June 2026.
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Netherlands: Culturally moving towards transparency. Expect new laws to meet the directive, including mandatory salary ranges in job postings, by June 2026.
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Spain: A frontrunner with strong pay transparency laws, including required pay audits. The culture has adapted quickly to these legal demands. Spain will update its laws to fully match all parts of the EU Directive by June 2026.
B. Non-EU European countries: A different pace
Countries outside the EU are not bound by the directive, but they are influenced by the trend and have their own approaches.
United Kingdom (UK):
Lay of the land: The UK has mandatory gender pay gap reporting for companies with 250+ employees. However, there is no legal requirement to post salary ranges in job ads. Culturally, pay has been private, but pressure is growing for more openness, partly influenced by the EU’s direction.
What to do: While not legally required, posting salary ranges is becoming a best practice to attract talent. Always follow the gender pay gap reporting rules.
Switzerland:
Lay of the land: Switzerland has a strong culture of privacy around salaries. There are no general laws requiring salary ranges in job postings. However, companies with 100+ employees must conduct an equal pay analysis. The push for transparency is growing, but it’s driven more by market competition for talent than by law.
What to do: To compete for international talent, consider posting salary ranges even if it’s not required. Ensure your equal pay analysis is done if you meet the employee threshold.
Norway:
Lay of the land: Norway has a culture of high social trust and relative openness. While there’s no law forcing salary ranges in job ads, gender pay gap reporting is required. The country is part of the EEA, so it often aligns with EU-style regulations and may adopt similar rules in the future.
What to do: Stay ahead of potential changes by adopting transparent practices. Follow the existing pay gap reporting requirements carefully.
III. The US rules: A mix of state and local laws
The US doesn’t have one big federal pay transparency law. Instead, many states and cities have their own rules. This creates a complicated situation for companies. These laws generally aim to make pay fairer by requiring salary disclosures and stopping questions about past pay.
Key state laws and when they start:
California (SB 1162): Started January 1, 2023. If you have 15+ employees, you must include pay ranges in all job postings.
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Colorado (Equal Pay for Equal Work Act): Started January 1, 2021. You must show salary ranges and a general description of benefits in all job postings.
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New York (Salary Transparency Law): Started September 17, 2023. You must show salary ranges for all advertised jobs, promotions, and transfers if you have 4+ employees.
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Washington (Equal Pay and Opportunities Act): Started January 1, 2023. If you have 15+ employees, you must show the wage scale or salary range and benefits in all job postings.
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Illinois (Public Act 103-0009): Started January 1, 2025. If you have 15+ employees, you must include the pay scale and benefits in all job postings.
Action for multi-state employers: If you operate in many US states, you need to follow all the different rules. It’s often best to aim for the strictest rule across all your locations to stay safe. Not following these laws can lead to big fines and legal trouble.
IV. Building a smart TA strategy: Your plan
To handle pay transparency well, TA leaders need a clear plan that combines following the rules with smart hiring practices.
A. Check your current hiring process
First, look closely at how you currently hire. This means checking job descriptions, where you advertise, how you talk to candidates, and how you make job offers. Find out what needs to change to meet the new pay transparency rules.
B. Create a clear pay philosophy
Have a clear plan for how you decide pay. This plan should explain how salaries are set (e.g., based on market rates, skills, experience, location) and how you keep pay fair inside the company. This gives you a solid base for talking about pay.
C. Write compliant job postings
Job postings are often the first place pay transparency rules apply. Here’s what to do:
Include salary ranges: Always put the minimum and maximum salary or hourly wage for the job, as required by law.
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Mention benefits: Give a general idea of benefits and other pay parts. This helps candidates see the full value of the job.
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Use simple language: Write clearly. Avoid confusing words so candidates easily understand the pay information.
D. Train your team: How to talk about pay
Your recruiters and hiring managers are key. Train them well so they know how to:
Discuss pay clearly: Talk about salary ranges, benefits, and your company’s pay philosophy with candidates.
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Handle questions: Be ready to answer candidate questions about pay transparency in a helpful way.
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Avoid illegal questions: Make sure they never ask about a candidate’s past salary.
E. Use technology to make compliance easy (that’s where Lyser comes in)
Trying to keep up with all these laws manually is tough and can lead to mistakes. Technology can automate and simplify things:
Automate salary info: Recruitment software can automatically add salary ranges to job postings, making sure you follow the rules for every job.
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Manage data and reports: Good platforms can track pay data, help with internal checks, and create reports for regulators.
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Connect your systems: Software that works with your Applicant Tracking Systems (ATS) and Human Resources Information Systems (HRIS) makes sure pay transparency data flows smoothly from hiring to managing employees. This saves time and makes data more accurate.
V. The Lyser advantage: Your partner in pay transparency
Lyser offers recruitment software designed to help TA teams handle pay transparency easily. Our platform builds compliance right into your hiring process, so you meet legal rules and attract great talent.
VI. Conclusion: Being open for a stronger future
Pay transparency is more than just a legal requirement; it’s a smart move for your business. By being open about pay, you can make your company more appealing, hire faster, and build a workplace based on trust and fairness.
Lyser is here to help you on this journey. We give you the tools and insights you need to make pay transparency compliance simple and clear. Step into the future of hiring with confidence.
VII. References
EU Pay Transparency Directive (Directive (EU) 2023/970)
UK Government: Gender Pay Gap Reporting
Swiss Federal Act on Gender Equality (GEA)
California Senate Bill 1162 (SB 1162)
Colorado Equal Pay for Equal Work Act
New York State Department of Labor: Pay Transparency Law
Washington State Department of Labor & Industries: Equal Pay and Opportunities Act
Illinois Public Act 103-0009
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