What pay transparency questions should HR teams be ready for?

TL;DR  

The EU Pay Transparency Directive, coming into effect in June 2026, will change how employers communicate about pay in policies and reporting. This we all know. However, many employers do not realize it will also have an effect in everyday conversations. 

HR teams should especially expect more questions from both candidates and employees. Some may be straightforward, others uncomfortable, but all will require clear, consistent answers grounded in process rather than personal judgement. It is therefore important to realize and keep in mind that preparation for the directive lies not only in compliance, but also in being ready to explain, discuss and stand behind pay decisions. 

In this blogpost, we have therefore decided to help this preparation and gather some of the most common questions employers can expect once pay transparency becomes a legal reality, and what HR teams should be prepared to answer.

Overview 

• Questions HR teams can expect from candidates
• Questions HR teams can expect from employees
• What these questions mean for HR teams preparing for pay transparency 

Questions you can expect from candidates

Q: In a job interview or throughout the application process, can I be asked about my current or previous salary?

A: No. Under the directive, employers are no longer allowed to ask candidates about their salary history. The aim is to prevent past inequalities from following candidates into new roles. For employers, this means pay discussions must be anchored in the role itself, not in what a candidate earned previously.

Q: When will you tell me the salary range of the position I am applying for? Will it be in the job ad or later?

A: Employers must share information about the starting salary or salary range either directly in the job ad or before the first interview. This requires HR teams to define salary ranges earlier in the recruitment process and ensure they reflect actual pay spans for the role.

Q: What if the salary range looks very broad. Can I ask for clarification?

A: Yes. Candidates are entitled to ask how pay within a range is determined. Employers should be able to explain what influences placement within the range (for example skills, experience, responsibility or market level) using objective, gender-neutral criteria.

Q: Can I negotiate outside the published salary range?

A: In practice, no. The published range is meant to reflect the real pay span for the role. While individual pay can vary within the range, systematically hiring above or below it would undermine the purpose of transparency and equal pay. This makes it important that salary ranges are realistic, well-defined and most importantly defensible.

Q: Will salary transparency therefore make it harder for me to negotiate?

A: Not necessarily, but it most definitely changes the nature of negotiation. Instead of negotiating blindly, candidates can discuss where they fit within a known range, and why. The goal of transparency is not to remove negotiation, but to make it more informed, fair and structured.

Q: Will transparency reduce bias in hiring?

A: Yes, that’s one of its core purposes. Clear salary ranges and criteria reduce the risk of arbitrary or biased pay decisions during recruitment, and help ensure that similar roles are compensated consistently. While the directive primarily targets gender-based pay disparities, greater transparency can also help reduce bias more broadly.

Q: Can my contract stop me from discussing my pay with colleagues?

A: No. The directive explicitly prohibits pay secrecy clauses. Employees are free to decide whether they want to discuss pay, and employers cannot restrict that right.

Questions you can expect from employees

Q: Can I see what my colleagues earn?

A: Not individual salaries, but employees do gain new rights. Employees can request information about:

• their own pay level, and
• the average pay level for employees of the opposite sex doing the same work or work of equal value

This information must be provided at group level and broken down by gender.

Q: What if I discover a pay gap between those two? Can I claim compensation?

A: Not automatically. If an unjustified pay gap is identified, the employer is required to assess the gap and create a concrete plan to address and reduce it. Compensation may come into play later, but the directive focuses first on correction and prevention.

Q: When do these rights apply to me?

A: The directive must be implemented into national law by June 2026. However, each country will set specific rules around timelines and procedures, including how long employers will have to respond to any information requests.

Q: Does this apply even if I work part-time, on a temporary or on a fixed-term contract?

A: Yes. The directive applies regardless of contract type.

Q: Does transparency also apply to promotions and internal moves?

A: Yes. The rules cover not only initial hiring, but also promotions, internal mobility and progression.

Q: Will this affect bonuses and performance pay?

A: Yes. The directive uses a broad definition of pay, which includes bonuses, variable pay and benefits. This means performance criteria and bonus structures will also need to be clear, objective and gender neutral.

Q: How can I raise concerns without damaging my relationship with my manager?

A: That is, of course, a hard question to answer. However, it is a directive and a legal process. Employees should therefore approach raising any concerns by referring to the process, not people. Employees can raise questions by asking for clarification based on formal criteria and rights under the directive, or by involving HR directly. This is another reason why clear documentation and communication matter.

Q: What proof do I need if I think my pay is unfair?

A: Employees don’t need to prove discrimination. If there are indicators of unequal pay, the burden of proof shifts to the employer, who must demonstrate that differences are justified by objective, gender-neutral reasons.

Q: Will pay gap reports be public?

A: That depends on the outcome. Public reporting is required in certain cases, particularly where gaps exceed defined thresholds. In other situations, employers may choose to publish voluntarily, but it is not always mandatory.

The takeaways

The Pay Transparency Directive will make pay conversations more frequent, more structured and more visible, but also more challenging for HR teams. The scope of these questions further proves how important preparation will be. HR teams that are prepared, with clear salary structures, defined criteria and reliable data, will be able to handle these conversations calmly and consistently. Those that aren’t may find themselves reacting under pressure.

Transparency doesn’t require perfection. But it does require readiness. So if you are ready and wanting to learn more, check out some of our other articles on the topic.

Or if you are interested in seeing how our platform may be able to help you once the directive comes into play,