Pay Transparency Directive: Turning a Constraint into a Performance Opportunity – an opinion piece by Grégoire Beaurain, International Director & Associate Director, Finance Practice at Grant Alexander for FocusRH
27.11.2025
Asking for pay alignment or requesting a clear explanation for a pay gap is still relatively uncommon today, largely because compensation remains a sensitive and confidential subject. Yet before long, any employee will be able to ask their employer for the average pay levels for colleagues carrying out comparable responsibilities.
France must implement the European Pay Transparency Directive, adopted in April 2023, by next June. With this legislation, HR departments will face a new reality: employees will be able to compare their situations and demand detailed explanations. It is therefore crucial to understand all the implications.
An additional administrative burden
Many organisations have not yet grasped the scale of the change — particularly SMEs and mid-sized companies — even though several measures will apply regardless of headcount. So what should they expect?
Very soon, employers will need to produce clear and precise HR indicators: comprehensive job frameworks, pay scales, comparison methodologies, and the objective criteria used in recruitment, promotion, and salary progression. They must also be able to publish and justify them. Employees will be entitled each year to obtain average salary levels, broken down by gender, category, and function, for work of equal value. Employers will have two months to respond to any such request.
In practice, the directive requires organisations to structure their remuneration policies around objective criteria: seniority, skills mastery, performance levels, and prevailing market pay.
Collecting and organising these data, documenting and justifying all HR practices, and building a coherent pay architecture will represent a considerable undertaking for many businesses.
How the directive changes the landscape
The directive will also have several other impacts on company life. Recruitment processes, for example, will change significantly, as candidates will have to be informed of the salary or salary range for the role before any interview takes place.
Managers will need training and support to adapt to these regulatory changes. From now on, every pay rise, bonus, and discrepancy will need to be documented, traceable, and defensible. Individual negotiations during performance reviews will be reshaped as a result.
Workplace dialogue will also evolve, as employee representatives will have access to far more detailed information.