Pay transparency: where does the transposition of the European directive stand?

While the European Directive 2023/970 on pay transparency must be transposed into French law by June 2026, the Ministry of Labour is gradually refining its position… and discussions with the social partners are in full swing. The consultation phase, open since March, will continue until the summer break. A welcome momentum, though not without debate.

“This directive is a tremendous opportunity for companies to accelerate their HR transformation, but it also means thoroughly reviewing their practices: recruitment, job classification, social dialogue… everything is concerned.”
Magali Covain

1. Towards a strengthened Professional Equality Index

First major change in the pipeline: the evolution of the Professional Equality Index, which would become more ambitious and would now be based on 7 indicators, including 6 calculated automatically via the DSN.
A clear way to highlight the importance of reliable, structured HR data.

Key takeaway: A “clean DSN” means a fairer Index — and less manual work for HR teams!

2. Recruitment: towards more transparency… and compliance

Another flagship measure, already prompting reactions: the obligation for job postings to state a salary range as well as the collective agreement provisions applicable to the role. A practice still far from widespread in France, but already well established in several European countries.

What’s at stake: greater fairness… but also the need for a clear salary mapping that is up to date and shared.

In addition, the question of previous salary, often asked during interviews, would now be prohibited, to avoid snowball effects from past inequalities.

This implies a skills uplift for recruitment teams, who will need to rely more on internal pay scales, observable skills, and clearly established levels of responsibility.

3. Strengthened administrative penalties

Lastly, the framework provides for strengthening the penalties applicable to companies that do not meet their obligations. In addition to existing criminal penalties, administrative fines could be introduced.

➡️ For HR leaders, the challenge is not only legal: it is reputational, managerial and financial.

Nothing is set in stone yet

France still has two years to transpose this directive, but it is more than time to anticipate the impacts. Pay scales, job classification, documentation of HR processes, recruiter training, preparation for social dialogue… there is a lot to tackle.

And if the devil is in the details, the steering of compliance lies in data and transparency.

“More than ever, this directive requires moving from declarations to evidence. It is a quiet but structuring revolution.”
Magali Covain

To Learn More

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