The four obligations with no staff threshold — the pay range in the job posting, the prohibition on asking about current salary, gender-neutral selection criteria and the information right of workers — are not something starting this year. They stem from the EU pay transparency directive, and their core has been established since the directive was adopted. What changes this year is mainly how individual member states have or are translating that core into national legislation, and whether enforcement and oversight are now in place.
For you as an employer, this means in practical terms: the obligations themselves are not new, but the extent to which they are already enforceable in your country may shift this year. Some member states had already met the transposition deadline, others are taking longer. This explains why two companies with the same question — do I now have to include a pay range in my job posting — may receive different answers, purely based on where they are established.
What does not change in substance
The four obligations with no threshold are called that because they do not depend on the number of employees you have. A company with five employees is in principle subject to the same extent as a company with five hundred. This distinguishes them from the reporting obligation, which does have a threshold. This core does not change this year: the directive itself is not being renegotiated, and the obligations it contains remain as they are.
What does happen this year is that more member states transpose the directive into their own legislation, with their own definitions, their own exceptions and sometimes their own additional requirements. A country might, for example, be stricter about what a gender-neutral criterion precisely means, or give a broader interpretation to the information right than the directive minimally requires. This is permitted: the directive sets a floor, not a ceiling.
What does change this year
Three developments are most noticeable for SME employers this year. First, in more countries the national implementation rules become concrete, meaning that vague expectations give way to testable requirements — for example, exactly what a pay range in a job posting text must look like. Second, supervisory authorities in some countries are beginning with guidance and initial inspections, even though a penalty framework is often not yet fully developed. Third, the number of information requests from workers is increasing as the subject becomes more widely known, simply because people know the right exists.
This last point is for many employers the first time the rules become practically tangible. Not through an inspection, but through a colleague asking how their salary compares to that of comparable roles. Those without a process in place yet — who handles the request, within what timeframe, with what substantiation — find that the question comes before the legislation is fully crystallised.
Why it differs by country
Because the directive is transposed via an interim period, member states are not moving at the same pace. A company with establishments in several EU countries may thus be confronted this year with a patchwork: in one country the pay range obligation is already fully implemented and enforced, in another the national law is still pending. This is not an inconsistency in the directive itself, but a consequence of how transposition works in the EU. For the exact status per country, national legislation or the competent supervisory authority is the appropriate source, not a general assessment.
For those who as an SME employer want to follow this without having to keep track of every legislative change themselves, you will find in the knowledge base sorted by topic an overview of what applies where and what still needs to be adopted. For those who prefer to first know whether this year will concretely ask something of them, here it is the compliance check with a few questions an indication based on the current state of affairs.
What you can do practically with it
Because the obligations apply without a threshold to every business, regardless of size, the most practical step is not to wait for clarity on enforcement, but to check now whether vacancy texts, job interviews and the handling of information requests align with what the directive aims for. This prevents you from having to adapt texts and processes afterwards that you had just set up.
Do you have questions about how payria.eu obtains this information and how it is kept up to date? That is explained on the page on how the information is created. For concrete doubts about your own situation, a lawyer or the competent supervisory authority in your country remains the appropriate contact point.
Do you want to know within half an hour where you stand this year? The free quick-scan and the knowledge base give you the short answer, the risk indication and the location in the official text — without needing an account for it.