The European pay transparency directive (2023/970 of 10 May 2023), which must be transposed into French law by 7 June 2026, is progressively taking hold across European organisations, imposing an unprecedented duty of transparency and explanation around pay. While its stated objective is to reduce unjustified gaps between women and men, the expected impact reaches well beyond the question of gender alone.

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France is nevertheless approaching this transformation somewhat later than other European countries. This can first be explained by a work culture historically marked by considerable discretion around pay: speaking openly about salary is often perceived as inappropriate, even taboo, both between colleagues and between employers and employees. While in France pay is seen as a marker of social and professional identity, the same is not true of some of its European neighbours, where pay transparency is already a reality. In the United Kingdom, for example, nearly 70% of job postings displayed precise pay information in 2024, compared with 50% in France [1]. In Norway, this culture of transparency is deeply rooted: any member of an organisation can, on simple request, find out what their colleagues earn — a system that has been in force for several years [2].

These examples illustrate a fundamental European shift, in which transparency is no longer perceived as a constraint but as a driver of trust, performance and fairness. France, by comparison, remains in a phase of learning and structuring, insofar as the transparency obligation directly challenges established habits, imposing an unprecedented openness on a subject long considered private. The transposition of the directive therefore represents a lever both for catching up and for social innovation.

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This directive prompts organisations to examine their managerial culture, their criteria for recognition and their relationship to the value of work. It requires rethinking HR practices, social dialogue and pay governance, in a logic of collective accountability and of coherence between stated values and lived realities.

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For organisations, the challenge is therefore as much cultural as operational: turning a regulatory constraint into a strategic and social opportunity.

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1. The expected effects of transparency

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Pay transparency cannot be reduced to a compliance exercise. By making gaps visible, it creates the conditions for a new conversation about pay — a topic that has long remained in the shadows. In its 2021 report, the OECD [3] confirms that pay transparency, especially when it forms part of a collective and regulated approach, contributes to reducing the gender pay gap. Transparency thus becomes a catalyst for progress, a trigger for constructive conversations and a means of strengthening trust within teams.

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But its most profound effect may lie elsewhere: in the questioning of the criteria used to assign value. This directive pushes organisations to ask themselves what they actually reward — performance, seniority, visibility, availability? Are these criteria gender-neutral? This reflection leads in turn to questioning the implicit hierarchy of career paths. A concrete illustration is emerging in the challenge to the priority traditionally given to managerial careers over expert trajectories. In a context where more and more people are turning down management roles in the name of meaning or work-life balance, pay transparency invites a rethinking of the very notion of recognition and of the progression routes available within the company.

It also opens the way to genuine HR innovation: some organisations are choosing to rethink their pay scales and to involve their teams in the co-construction of pay policy. The online bank Shine, for example, published an openly accessible salary grid in 2018 combining role, level of expertise and a "dependants" bonus, in order to standardise its pay decisions and make them transparent [4]. At Decathlon in Belgium, following the introduction of the Individual Social Report (Bilan Social Individualisé) to clarify each person’s benefits and pay, a process now allows employees to request a raise on the basis of their peers’ assessment [5].

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Pay transparency offers an opportunity to review the dimensions an organisation values and to correct the biases running through evaluation and promotion processes.

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2. The issues raised by this evolution

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To turn this directive into a lever for social cohesion — into an opportunity rather than a source of tension — organisations must address several major issues: organisational, managerial and cultural.

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Issue 1: Transforming HR and managerial practices

The obligation to publish pay gaps by professional category and by gender implies changes to HR policies, mechanisms and processes, the scale of which depends on the starting point: overhauling pay scales, clarifying progression criteria, ensuring the traceability of pay decisions, and so on. To make these changes tangible, the work cannot be confined to HR teams: managers must be trained to detect bias and to conduct more transparent and educational discussions about pay. This technical requirement becomes a lever for managerial maturity.

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Issue 2: Strengthening social dialogue and a culture of fairness

While the intention appears ethically commendable, transparency makes visible realities that are sometimes uncomfortable, and which can generate jealousy, misunderstanding or a sense of injustice. Far beyond equality between women and men, it is fairness across the organisation as a whole that is called into question — hence the relevance of bringing the subject into social dialogue. Employers face the need to justify themselves, and even to adapt pay policy to the diversity of aspirations and contributions.

With access to better information, members of the organisation gain autonomy in their discussions with HR and with managers. Once the basis for reward is made explicit, it can become a lever for engagement and retention. To avoid tensions and misunderstandings, organisations have every interest in setting up spaces for discussion and co-construction around the criteria for reward and recognition.

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Issue 3: Attractiveness, retention and employer brand

A study by Welcome to the Jungle finds that a job posting displaying the salary receives 48% more visitors than one without, and 22% more applications [6]: transparency is already a major factor in attractiveness. Organisations that own and explain their pay policies strengthen trust and talent retention by positioning themselves as responsible and consistent employers. Transparency conveys the message of an employer committed to fairness and to the proper recognition of the individuals who make up the organisation.

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Issue 4: Governance and risk management

The directive requires regular reporting on pay gaps, along with assurance of its reliability and traceability. Consequently, where a gap is unjustified, the risk of litigation is all the greater. The task is therefore to integrate pay transparency into social risk management and internal governance. Strengthened governance helps limit drift, but also makes it possible to anticipate inspections and to secure the organisation.

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Issue 5: Evolving the organisation’s culture

Moving from a culture of confidentiality to a culture of transparency takes time — from a few months to several years depending on the context — and calls for education. It is a genuine paradigm shift: learning to talk about money without taboo, to explain reward decisions and to stand behind their coherence. It therefore requires an effort of cultural transition, grounded in education and communication at every level of the organisation.

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3. A gradual and shared trajectory

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Success will come neither from a decree nor from transparency imposed overnight. It requires a gradual trajectory involving every level of the organisation. The starting point must be a shared, factual diagnosis that makes it possible to understand the gaps and identify their causes. Leadership teams have a key role here: initiating the reflection on reward criteria and standing behind its coherence.

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Moreover, this work cannot be carried out in a silo. It must mobilise those in positions of responsibility, employee representatives and managers in an approach of shared accountability. This can take the form of strengthened social dialogue, awareness-raising workshops or participatory diagnostics. Individuals themselves can then become agents of transparency by getting involved and sharing their own perception of added value. This collective ownership will need to build gradually until it permeates every level of the organisation. Transparency then becomes a collective project rather than a mere regulatory compliance exercise.

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4. Pitfalls to avoid

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Several risks threaten the success of the process. First, the non-gendered approach required by the directive may, on the contrary, lead to polarisation between men and women. Questioning criteria that favour certain social groups is far from securing everyone’s agreement, particularly in light of the French conception of discrimination.

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Another pitfall would be an abrupt, unprepared transition from total opacity to radical transparency. This would open the door to a wide range of interpretations and to interpersonal tensions. Poorly supported, this kind of revelation can generate more frustration than answers.

The psychological contract between employer and employee is made up of promises — whether about principles and values or about recognition. When those promises turn out not to be kept, trust risks breaking down, and credibility can be laborious to win back. The whole challenge of this adaptation lies in finding a balance between the requirement for clarity and caution in the rollout.

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A further risk relates to payroll inflation when the approach is poorly anticipated. Insufficiently framed transparency can trigger a chain of claims and create social tensions that are difficult to contain. The challenge is to avoid overly rapid or uncontrolled adjustments, which would undermine economic sustainability and overall coherence.

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Finally, a last pitfall concerns the difficulty of objectifying certain criteria: behaviours, cooperation, engagement or qualitative contribution. These dimensions often escape strictly "objective" measurement. Some organisations are experimenting with tools whereby teams "rate" their colleagues: a possible option, but one that amounts to institutionalising the "like" as an evaluation criterion. Such a development raises ethical and cultural questions that must be anticipated very early on.

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5. A lever for equity and performance

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Pay transparency is not only a tool of social justice; it is also a lever for organisational performance.

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First, it introduces a collective dimension in which every actor is given responsibility. Second, by encouraging coherence and traceability, it improves the quality of management and the robustness of HR policies.

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The return on investment is compelling: companies such as Smappen, a platform specialising in geomarketing, and Clinitex in the cleaning sector [7] have shown that this kind of openness can defuse tensions and strengthen collective spirit. Similarly, at Alan [8], pay discussions have become calmer; at 360Learning [9], progression prospects within the company are visible, which fosters engagement and individual responsibility. At the end of a successfully managed change process, organisations can benefit from a calmer social climate, greater engagement and better talent retention.

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6. Conditions for success

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Transparency challenges the implicit system of recognition and differentiation. Resistance is reinforced by fear of change, apprehension about social instability and the difficulty of letting go of long-standing HR management practices. That resistance is all the stronger where pay transparency is experienced as an external injunction (a European directive, a decree) rather than as a voluntary initiative.

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Beyond the technical reflections on job evaluation or pay criteria, four conditions appear essential to implementing pay transparency:

• Embedding the approach over time, offering gradual ownership — from the quantified picture to the questioning of biases, from the Executive Committee through to the teams;

• Favouring an approach that is tailored and differentiated for each stakeholder group, in order to anticipate and defuse potential resistance and concerns (top management, line managers, managerial staff, non-managerial employees, trade unions, etc.);

• Equipping managers and HR, who will be the main relays for the messages to be conveyed in support of the change, through training, ownership workshops, communication tools and opportunities for open dialogue;

• Tracking progress with clear, shared indicators that go beyond the regulatory pay gaps (e.g. satisfaction rates, the progression of women within the organisation, the number of claims handled), so as to create a credible trajectory with measurable commitments.

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The effectiveness of such a transition rests on a trajectory that is realistic, financially sustainable and culturally appropriate. The directive thus becomes a structuring framework for lasting change.

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Sectors are unequally exposed to the difficulty of implementation, so the trajectory will also have to take sector-specific realities into account:

• Industrial sectors and SMEs / very small businesses, where pay management is little formalised and highly personalised, will face the greatest difficulty in applying the directive. They will have to structure their HR policies and justify every pay gap, which amounts to a profound transformation.

• Sectors and roles with a large variable component (sales roles, banking, insurance, consulting) will have to clarify and objectify complex pay systems on the basis of quantified data, which may generate internal tensions and resistance.

• Sectors where pay scales are already public (the public sector) or highly structured (some large CAC 40 companies) will be less affected, even if individual publication remains a sensitive matter.

• In health and social care, transparency will highlight the under-valuation of certain occupations, prompting pay reviews.

• The digital and tech sector, although more open to transparency, will have to manage the diversity of employment statuses and competition for talent.

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Conclusion

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Beyond a mere compliance exercise, the pay transparency directive can become a genuine opportunity. It is a demanding standard that requires changes in HR practices, social dialogue, governance and organisational culture. But with the right level of support and strategic reflection, it becomes an opportunity for organisations to revisit their practices, strengthen trust and realign their values. The directive calls for collective reflection on what the organisation values, on how contributions are recognised, and on the coherence between what is said and what is done. Provided it is properly supported and shared, pay transparency can become a powerful lever for cultural transformation, in the service of greater equity and sustainable social performance.

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[1] Lisa Feist, Salary Transparency in Europe: Building Trust, Closing Gaps, Indeed Hiring Lab, 2025.

[2] Lars Bevanger, Norway: The country where no salaries are secret, BBC News, 2017.

[3] Pay Transparency Tools to Close the Gender Wage Gap, OCDE, 2021.

[4] Mathilde Callède, La transparence des salaires chez Shine, Shine, 2022.

[5] Mélissa Darré, Rémunération : ces phrases que vos salarié·e·s ne veulent plus entendre, Welcome to the Jungle, 2021.

[6] Welcome to the Jungle & IPSOS, Baromètre de la marque employeur, 2023.

[7] Transparence des salaires : ces entreprises françaises qui l'appliquent déjà, France Info, 2025.

[8] Jean-Charles Samuelian, The right pay: our public pay scale, Alan, 2023.

[9] Nicholas Wagner, Why We Don’t Negotiate Salaries at 360Learning, 360Learning.