The EU will implement strict pay transparency laws to make pay data public by 2026, while the UK continues to focus on gap reporting and market trends. EU rules force companies to share pay ranges in ads, but the UK does not yet have a national law that requires this practice.
What being open about pay means in the EU
The EU Pay Transparency Directive changes how companies hire and pay.
- Companies must share pay ranges on ads or with job seekers before an interview.
- Managers cannot ask people about what they earned in past jobs.
- Staff can ask for data on average pay levels for people who do the same work.
EU member states are under an obligation to develop the directive into a national law by June 2026.
What being open about pay means in the UK
Large firms in the UK still focus on gender pay gap reports.
- Many firms now share plans that show how they will close pay gaps.
- Most job ads show salary ranges because candidates want them, not because a law exists.
- The UK could potentially catch up with the EU by running its own transparency directive.
Practical next steps for HR teams
HR teams that hire in both areas often follow the stricter EU rules everywhere. This makes it easier to manage remote workers and keep pay fair across all teams.
Firms should build clear pay bands and keep notes on why they pay a person a certain amount. Using one set of rules helps teams avoid extra work if the UK changes its laws later. It also helps a company stay competitive.
Limits and gaps
EU states might set rules that go beyond the basic directive. In the UK, rules might change as the government talks with businesses. Many firms choose to be open about pay now so they are ready if the laws get tighter.
TL;DR
- The EU will impose strict laws to make pay data public by 2026, while the UK still focuses on gap reporting.
- In 2026, EU jobseekers will see pay ranges on job ads, and staff will gain a legal right to see how their pay compares to others.
- HR teams in both regions often follow EU rules to keep their pay bands fair and clear.