Regulation in PracticePay Transparency: focusing only on compliance means missing the biggest opportunity
Pay Transparency demands more than a report. It forces organisations to explain how roles, growth and reward relate to one another. And that is precisely where the opportunity lies.
Björn Slegers ·
The European rules on Pay Transparency are often approached as a new compliance exercise. Gathering data. Calculating pay gaps. Reporting. Explaining discrepancies. That work will be necessary. But anyone who stops there will probably miss the most interesting part of the change. After all, Pay Transparency poses a more fundamental question: can your organisation explain why someone earns what they do?
Not just to an auditor or employee representative. But also to a candidate, an employee, a manager and, ultimately, to itself.
First, the legal detail
The European Pay Transparency Directive had to be transposed into national law by 7 June 2026 at the latest.
Belgium did not meet that deadline and has asked the European Commission for an additional six months. In the meantime, work has continued, including with the social partners. This request for an extension does not in itself change the original European deadline. For Belgian employers, it is therefore important to bear two things in mind at the same time.
The precise Belgian implementation is still in flux. The European direction is not.
The directive provides for, among other things, greater transparency during Recruitment, objective and gender-neutral criteria for pay setting and pay progression, information rights for employees, and reporting on pay differences.
For employers with at least 250 employees, the directive requires reporting from 7 June 2027 and annually thereafter. Employers with 150 to 249 employees also start in 2027, but then report every three years. For organisations with 100 to 149 employees, periodic reporting under the directive starts in 2031.
That is relevant legal context. But it is not the most important reason to start today.
Above all, transparency exposes what has not yet been designed
Many organisations have salaries. Fewer organisations have a true reward system. History, individual negotiations, scarcity, promotions, acquisitions and manager decisions have added layer upon layer over the years. As long as no one asks why two roles are paid differently, that system can continue to work for years.
Transparency changes that. Suddenly, an organisation must be able to explain which roles are comparable, what 'work of equal value' means, which criteria explain pay differences, and how someone grows within a pay structure. An exception can be perfectly defensible. But someone still needs to know why it was ever made.
That is why Pay Transparency is much more than a reporting question. It is organisational design.
That's where the opportunity lies
Good preparation can force an organisation to finally tackle issues that have been around for much longer. Roles become clearer because you have to understand the responsibility and value attached to them. Internal mobility becomes simpler when levels and expectations do not just exist implicitly in the minds of managers.
Reward conversations become stronger when a manager no longer has to fall back on 'that’s just how it evolved'. And discrepancies become more interesting. A pay difference is not automatically a problem. A difference that no one can explain, however, may well be. That also changes the role of data. The intention is not for a percentage to decide whether an organisation is doing things right or wrong.
Data shows where it makes sense to look deeper. That is where the real work begins.
So do not start with the report
The temptation will be great to first determine which fields are needed for the statutory reporting. We would start differently. Have roles truly been made comparable? Are all relevant pay components available? Can historical decisions be traced? Are the criteria for growth explicit? And can managers also use those criteria when they sit down with an employee?
Anyone who gets that in order today is not just preparing for a directive. They are building an organisation in which reward decisions become less dependent on memory, negotiation and chance. Perhaps that, ultimately, is the most important form of transparency. Not that everyone earns the same.
But that differences are explainable.
Pay Transparency in Almuruna One