What the EU pay transparency directive requires

The EU pay transparency directive (Directive EU 2023/970) requires employers to disclose pay and pay structures and to make gender-based pay differences visible. The goal is to enforce equal pay for equal or equivalent work. Member states had to transpose the directive into national law by 7 June 2026.

The picture in mid-2026 is sobering, however: most EU states have missed the deadline, including Germany. So far, only a few countries have fully implemented the directive. That does not change the direction. It does change the pace, and that is exactly what makes this moment interesting for forward-looking employers.

For recruiting, the directive brings four key points:

1. Pay information before the interview: employers must state the starting salary or a salary range, either in the job posting or at the latest before the first interview.
2. Ban on asking about previous pay: candidates may no longer be asked about their pay history, meaning their current or previous salary, so that old pay gaps are not carried from one job to the next. The question about salary expectations is not affected.
3. Right to information: employees can request information about their own pay level and about the average pay levels for equivalent work.
4. Reporting duty: larger employers must report regularly on gender-based pay differences[¹].

Does the pay transparency directive apply to Swiss companies?

The pay transparency directive does not apply directly to purely Swiss employment relationships. Switzerland is not an EU member and is therefore not required to implement it. The directive does become relevant for Swiss companies in three cases:

• When they employ staff in EU states.
• When they run subsidiaries in the EU.
• When they recruit across borders.

There is a second, often underestimated point. Whoever competes for the same talent as employers in the neighbouring EU will soon compete for their expectations too. A candidate choosing between a Swiss and a German offer does not compare legal systems. She compares who is transparent and who is not.

What matters in recruiting

In day-to-day recruiting, the directive comes down to two simple moves: one piece of information is added, one falls away. The salary range becomes visible. The question about previous pay falls away.

That sounds like a detail, but it shifts the logic of the hiring conversation. Pay is no longer the result of a negotiation about the candidate's past, but a statement about the value of the role.

One distinction matters here that often gets lost: what is banned is the question about previous pay, not the question about salary expectations. Asking about a person's expectations remains allowed, and it makes sense. It becomes clean when the salary range comes first. If you state the range in the posting and then ask about expectations, you have a conversation on equal footing. If you only ask about expectations without ever stating a range, you risk exactly what the directive wants to prevent: that low expectations are paid low. Which questions on the application form still make sense today is therefore worth a second look.

Whether salary information belongs in the posting at all is something we have already weighed up in detail, with all the arguments for and against: salary in job ads, yes or no. The directive now answers this question for the EU by itself.

The Swiss reality: 63 percent expect it, a third delivers

Pay transparency is not a distant EU question in Switzerland, it is already an expectation. According to the HR Trends Switzerland 2026, 63 percent of candidates and 57 percent of employees expect more clarity on pay.

Practice tells a different story. In a JobCloud pay study, only about a third of companies were willing to disclose salaries, 61 percent were not[²]. This gap between expectation and reality is not a risk. On the contrary, it is an opportunity. Whoever states a salary range now stands out in a market where most still stay silent, and makes transparency part of their employer branding.

What Swiss employers can do now

Whether or not the directive legally applies to you, the market is moving in one direction. These five steps get you there before you have to:

1. Define a salary range and state it. Set a defensible range for each role and communicate it in the posting or at the latest before the first interview.
2. Drop the question about previous pay. Remove it from the application form and the interview guide. Pay follows the role, not the person's past. You may still ask about salary expectations, ideally once the range is on the table.
3. Review your internal pay structure. Before ranges go public, the internal logic should hold. A pay equality analysis shows where it does not.
4. Make pay differences defensible. Where people earn differently for equivalent work, you need objective, documented criteria such as experience or responsibility.
5. Brief HR and managers. Anyone running interviews must know the salary range, understand the right to information, and know the difference between the allowed question about salary expectations and the sensitive question about previous pay.