Beyond the pay gap #6

Embracing a culture of pay transparency and engagement

Two people looking at a document standing infront of an office meeting room
  • Insight
  • 5 minute read
  • July 17, 2026

The EU Pay Transparency Directive (EU PTD) is more than a compliance task—it's a cultural shift. By moving away from secrecy towards more open conversations about pay, the EU PTD gives you the chance to enhance your employer brand, attract talent, and build greater trust with employees while improving engagement and performance. A minimal 'tick-the-box' approach to the EU PTD could harm employee trust and overwhelm managers. So, what distinguishes basic compliance from exemplary compliance, and how can you achieve this?  

Handled effectively, the EU PTD is a chance to demonstrate your dedication to pay fairness and transparency. 

But what if? What if they're inconsistent or employees feel they're not getting the full picture? 

 Employee motivation and performance could decline if disclosures uncover entrenched pay gaps. Failing to explain or justify these gaps could also lead to legal claims, wherein you must prove that pay is fair and compliant.

The EU PTD is intended to address these opportunities, risks, and organisational impacts. 

Pay transparency will end restrictions or taboos about discussing salaries. Empowered employees will compare salaries and judge whether their pay is fair.

Is your organisation ready?

Further questions centre on your organisation's readiness to handle the EU PTD's impact.

For HR, this means major changes in recruitment practices and salary negotiations. HR teams will also face a surge of employee requests for information.

Leadership teams must explain salary differences with less room for subjective justifications.

For employees, comparing salaries with peers strengthens their position to discuss pay. They'll question if they're being paid fairly and how they can advance their earnings by developing new skills.

With more employee questions, line managers will need to understand pay structures, know team members' earnings, and justify pay decisions. They also need training to confidently handle challenging pay conversations.
 

Proactive fairness assessmentsManager-led engagementsPay as a shared responsibilityA culture of openness and dialogueThe cultural leapA culture of secrecyPay as a private matterHR-owned conversationsReactive explanations

Organisational readiness demands consistent leadership, decision-making, and messaging. If the cultural impact isn’t actively addressed, pay policies and procedures won't build trust.

What's your ambition?

Ambitions vary when it comes to pay transparency. But merely complying will make it hard to address opportunities, risks, and cultural impacts.

Raising your ambitions lets you actively shape and optimise your workplace culture. The keys to achieving these ambitions are preparing your managers and effectively communicating your pay philosophy.

 

ComplianceGo above and beyond to act as a role model in our industry, or even beyondDifferent levels of change ambitionDrive a cultural shift to retain and attract top talentChange ManagementMinimalistPragmatistStrategistTrailblazerLeverage greater transparency as part of our people strategy, to gain a competitive advantageManage change for a smooth roll-out and avoid unfavorablereportingDo everything we need to do to stay in complianceCreate a long-term change strategy and build lasting capabilities for all stakeholdersSupport managers in actively address concerns and guide employees through transition smoothlyMinimal engagement focuses on delivering essential knowledge quickly

As we've learned from working with organisations implementing the EU PTD, moving from minimum compliance to doing it well can be achieved with less effort and investment than you might think.

On the flip side, minimal compliance can be a false economy. Employees may assume you don't care about fairness and transparency. You also risk overloading line managers, who must explain and justify pay disparities they don't fully understand or control. Ultimately, this is a missed opportunity to create a culture valuing openness and dialogue, and to gain an edge in attracting and motivating talent.

What does complying well look like?

The foundation is a well-designed pay philosophy outlining pay structure, employee expectations, and the role of fairness and transparency. Your job architecture will show how effectively this philosophy is applied across your organisation and which workforce sections need targeting to address gaps

The next priority is ensuring the information and justifications you provide are coherent and credible. Minimum disclosure may not be enough. When responding to Right to Information requests, for example, the only data required is the unadjusted average pay for men and women in the employee's peer group. But this minimum disclosure doesn't account for important differences in education, skills, or location, which may explain why an employee’s pay is positioned lower than the average. Proactively explaining or adjusting for these differences helps justify disparities

Addressing these priorities means showing you approach fair pay seriously and thoughtfully, both in disclosures and responses to signs of inequality. With increased transparency, any gaps between what's said and done will quickly become evident and potentially damaging.

What practical steps can you take?

Drawing on our work with various organisations, three focus areas stand out:

Clear ambitions help develop a clear roadmap for change and set performance objectives to measure progress and target interventions.

Defining what transparency means for your organisation and how it fits into your pay philosophy also helps develop a clear and compelling communication strategy. Determine what's changing, why it's important, and how your employees will benefit.   

You can inform and guide the pay conversation by using the EU PTD as an opportunity to educate management and employees about how pay is structured and applied.

It's also important to ensure key stakeholders are ready to play their part in implementing the EU PTD and address the wider impact on employee engagement and trust. HR, leaders, and employees all have roles to play here—but managers face the most significant change.

Preparations for HR

HR must be ready to explain pay and pay progression to employees, but also to actively safeguard pay equity by making fair and defensible pay decisions at each stage of the employee life cycle. Every pay decision matters, every deviation needs documentation, and every exception could be a risk. Managers and leaders will also lean on HR business partners and reward teams for help with managing tricky pay situations, increasing already heavy HR workloads.

Preparations for leadership

By developing a clear communications strategy and setting the tone from the top, leadership teams need to make it clear to line managers that pay transparency matters. They also need to be at the forefront of shaping the pay philosophy, understanding its application, and how it influences strategic decisions in areas like recruitment.

Preparations for employees

Employees will be presented with crucial new information about their pay and relative positioning. This may take effort to fully understand, but it will also make them ask "Am I being treated fairly?" and "Is this a workplace I want to stay in?"

 


If line management gets it, you'll see the benefits of the EU PTD. 

Line managers are the first point of call for pay conversations. They're also pivotal in shaping your organisation's culture.

Many organisations tell us their managers only have a basic understanding of pay. They don't expect in-depth pay discussions with their reports. Though often underestimated, it’s crucial to empower line managers with necessary skills and tools to face the new and potentially unfamiliar demands ushered in by the EU PTD.

Empower your line managers

Some organisations worry line managers might say or do the wrong thing regarding the EU PTD. They want line managers to pass pay transparency matters to HR. The problem is HR could be overwhelmed, especially as many enquiries need to be addressed by a limited number of reward specialists. This 'outsource to HR' approach could also cut out positives from deeper, more personalised pay conversations.

A more balanced approach positions line managers as the first contact, escalating more technical enquiries to HR as needed. This requires training and briefing, but it enhances pay engagement and strengthens trust without overloading line management or HR.

The third approach fully empowers line managers to discuss pay and take the lead in ensuring fairness. To do this, they need to understand why pay is structured as it is, how to assess it for fairness, and when to raise issues with HR if they spot potential disparities.

Educating and equipping your line managers

A few e-learning slots aren't enough to get line management up to speed with their responsibilities. They need targeted training and guidance on engaging with employees on pay and regular briefings to back this up.

Knowledge:

  • How pay is structured in your organisation

  • Legal requirements and employee rights under the EU PTD

  • Where to find information (pay scales, peer benchmarks)

Skills:

  • How to handle difficult conversations (e.g., "I think I'm underpaid")

  • How to explain pay decisions objectively

  • How to link pay discussions to career development conversations

Tools:

  • Scripts for common scenarios

  • FAQs

  • Clear escalation protocols

  • Incentives, with results tied to bonuses and progression

 

Effective measurement helps assess readiness, track progress, and gauge the impact on employees and the organisation.

Key measures include pay awareness and knowledge levels within management. It's also important to gauge trust in pay practices, the quality of pay discussions, and their impact on employee satisfaction and retention.

The results help test your pay philosophy, map gaps, and focus interventions where they can make the most difference.

Are you up to speed?

Pay transparency is coming, whether you're ready or not. The big question is: will you lead the change or merely react to it?

Treating the EU PTD as a cultural opportunity rather than a compliance burden will:

  • Build deeper employee trust and engagement

  • Strengthen your employer brand and talent attraction

  • Reduce pay-related grievances and legal risk

  • Create more capable and confident managers

  • Establish fairness as a living reality and source of competitive advantage, not just a policy

To thrive under pay transparency, you need to take action now:

  • Diagnose your readiness

  • Build manager capability

  • Refine your pay philosophy

  • Shift your culture consciously and systematically

In the coming article in our Beyond the pay gap series, we'll explore where organisations are now, what more they need to do, and how they can accelerate implementation to realise the benefits of pay transparency.

Let's talk

You can read previous articles in our Beyond the pay gap series here. If you’d like to discuss any of the issues raised in these articles or learn more about how the EU PTD will affect your business, get in touch. You can find our details below. 

About the author(s)

Petra Raspels
Petra Raspels

Partner, Co-Lead Workforce Transformation, PwC Germany

Johannes  (Joop) Smits
Johannes (Joop) Smits

Partner, People and Organisation, PwC Switzerland

Mareike Kusch
Mareike Kusch

Manager, PwC Germany

Alexander  Skumiewski
Alexander Skumiewski

Senior Manager, People and Organisation, PwC Switzerland

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