EU pay transparency: what changes in senior offers

Juan Molina ·

The EU pay transparency deadline passed on 7 June 2026 and most countries missed it. What hiring leaders should do with senior and executive offers in Europe anyway.

A candidate for a VP role in Europe asks, in the first call, what the role pays. Until recently many companies answered with a question about the candidate's current salary. Under the EU Pay Transparency Directive, that exchange is reversed, and the first answer belongs to the employer.

What the directive requires

The European Commission summarized the rules on 5 June 2026. Employers must give candidates the starting salary or its range, either in the vacancy notice or before the interview, and may not ask candidates about their pay history (European Commission, 5 June 2026). Employers with at least 100 employees must report on the gender pay gap, and where a gap of 5% or more cannot be justified by objective criteria, a joint pay assessment follows. The Commission puts the EU gender pay gap at 11.1% (European Commission, 5 June 2026).

None of this exempts senior roles. The rules apply to the vacancy, whatever the level.

Where national laws stand

Member states had to transpose the directive by 7 June 2026. According to Deloitte's update as of 12 October 2026, only Italy, Lithuania, Malta and Slovakia met that deadline; Greece's law takes effect on 1 November 2026 and Estonia has transposed it in part (Deloitte Legal, 12 October 2026).

Other dates are still moving. Deloitte reports that the Czech Republic is likely to start on 1 January 2027 and the Netherlands is aiming for the same date. Denmark expects 1 March 2027 and will require the range to be disclosed before the interview. France plans to apply its rules from 1 January 2028, and Spain's process has been delayed by an election (Deloitte Legal, 12 October 2026).

So a company hiring across Europe faces a patchwork: some countries in force, some close, some later. Each national law can add its own details.

Why waiting is the harder path

The tempting choice is to wait until each country's law applies. I think that is harder in practice. Senior searches often run across several countries at once, and candidates compare. If an offer in one country must show a range and the same role in another does not, you are running two pay conversations for one job.

The more durable decision is to set a defensible range for each senior role now, based on the work and the market, and to stop asking for current salary everywhere. That also helps with candidates from outside the EU, including senior leaders in Latin America, because the conversation starts from what the role is worth, not from what they earned before.

Executive packages add complexity: bonuses, equity and benefits. The Commission's summary refers to pay and its range (European Commission, 5 June 2026); how each country treats variable pay is a question for local counsel.

What to do this week

  • List every open or planned senior and executive role in an EU country, with the country.
  • For each country, check its transposition status against the Deloitte tracker and note the start date.
  • Remove current-salary questions from your application forms, scorecards and recruiter scripts.
  • Write a pay range for each senior role, with the reasoning behind it, before the next search opens.
  • Ask local counsel how variable pay and equity should appear in the range in each country you hire in.