By Team Weltis
Pay Transparency: What HR and Business Owners must do by June 2026 (EU Directive 2023/970)
Financial wellbeing - 30 April 2026
Hi HR 👋🏻
On June 7, 2026, the European Pay Transparency Directive comes into force in Italy. On the surface, it looks like the typical regulatory update, like so many others. In reality, it is a paradigm shift in how money is discussed within companies.
From that date, your employees will have the right to request and obtain information on average pay levels within their professional category, broken down by gender. Within two months of the request, you will be required to respond. In writing. There is no way around it.
If you have at least 100 employees, you will need to periodically report the gender pay gap within your organization. The data will be made public.
And if that gap exceeds 5% without an objective justification? Well, a joint pay assessment with employee representatives becomes mandatory.
None of this is science fiction — it is a law already in force, and there are just a few weeks left until it applies in Italy and all other EU member states.
Why This Law Exists (and Why It Concerns You Too)
The gender pay gap in Europe is still at 12%. This means women earn on average 12% less than men.
In Italy, despite equal opportunity legislation having existed for years, the lack of transparency has made it nearly impossible to enforce the principle of equal pay.
Directive (EU) 2023/970 was born precisely from this: without transparency, pay discrimination remains invisible. And what cannot be seen cannot be changed.
It also frequently happens that many companies discover pay gaps they were not even aware of. Often linked to subjective assessments during hiring, asymmetric salary negotiations, or simply the fact that no one had ever lined up the numbers.
And when the numbers surface without a clear pay structure behind them, questions follow. And they are not easy ones.
What Concretely Changes from June 7, 2026
🔍 Before Hiring: Transparency from the First Contact
When you post a job listing, you will need to state the starting salary or pay range for that position. You can no longer ask candidates what they currently earn or have earned in the past.
The goal is to eliminate the information asymmetry that disproportionately disadvantages women (and anyone coming from underpaid sectors). If a candidate does not know what that position is worth, they start at a disadvantage. And they often accept less than would be fair.
For you, this means: defining pay ranges for each role in advance, based on objective criteria. No more improvising during negotiations.
Article 5, paragraphs 1 and 2 – Directive (EU) 2023/970 «Job applicants have the right to receive [...] information on the starting salary or its range to be attributed to the position [...] in such a way as to ensure an informed and transparent negotiation. The employer may not ask candidates about the salaries received in current or previous employment relationships»
📊 Right to Information for All Employees
Every worker will be able to ask you, at any time:
Their individual pay level
The average pay levels of the category of workers performing the same work or work of equal value, broken down by gender
You have two months to respond. In writing.
The employee can make the request directly, through employee representatives, or through the Equal Opportunities Counsellor.
What does work of EQUAL VALUE mean? It is not enough to compare identical roles. The law requires evaluating different roles based on four objective criteria:
Required skills
Effort (physical, mental, emotional)
Responsibility
Working conditions
Concrete example: a call center operator and a maintenance technician may be considered of equal value if, applying these criteria, the two roles prove equivalent in terms of complexity and contribution to the company. If one of them earns significantly less, and the difference is linked to the gender predominant in that role, you are in a risk zone.
Article 7, paragraphs 1 and 4 – Directive (EU) 2023/970 «Workers have the right to request and receive in writing [...] information on their individual pay level and on average pay levels, broken down by sex [...]. Employers shall provide the information [...] in any event within two months of the date on which the request is made»
📈 Mandatory Pay Gap Reporting (if you have at least 100 employees)
The timelines are clear:
250+ employees
First deadline: June 7, 2027
Frequency: Annual
150-249 employees
First deadline: June 7, 2027
Frequency: Every 3 years
100-149 employees
First deadline: June 7, 2031
Frequency: Every 3 years
The data to be reported includes:
Average gender pay gap
Gap in variable components (bonuses, overtime, benefits)
Percentage of women and men per pay quartile
Pay gap by worker category
This data will be collected by the Ministry of Labour and made public. Anyone will be able to compare your company against competitors in the same sector.
Article 9, paragraphs 1 and 7 – Directive (EU) 2023/970 «Member States shall ensure that employers provide information [...] on the gender pay gap. Such information shall be published by monitoring bodies [...] in an easily accessible and usable manner, allowing easy comparison between employers, sectors and regions»
Art. 9, paragraphs 1 and 8 – Government Act No. 379 (article still pending parliamentary approval) «The data subject to reporting [...] are those relating to: the gender pay gap [...] including complementary or variable components; the median gap; the percentage of workers in each pay quartile. For employers with at least 250 employees the data are collected by June 7, 2027 and annually thereafter; for those between 150 and 249 employees [...] every three years; for those between 100 and 149 employees [...] by June 7, 2031 every three years»
⚠ What Happens if the Gap Exceeds 5%
If the average pay gap between women and men in any worker category exceeds 5%, and you cannot justify it with objective criteria (e.g. seniority, certifiable skills, actual responsibilities), a joint pay assessment becomes mandatory.
This means sitting down with employee representatives and:
Analyzing the causes of the gap
Defining corrective measures
Implementing them within a reasonable timeframe
Reporting the plan to the Ministry of Labour
This is not merely an accounting exercise, but a process of structural review of pay policies.
Article 10, paragraph 1, letter a) – Directive (EU) 2023/970 «Member States shall take appropriate measures to ensure that employers [...] carry out, in cooperation with their workers' representatives, a joint pay assessment where [...] pay information reveals a difference in the average pay level between female and male workers of at least 5% in any worker category»
The Italian Case: the Role of the CCNL and the Presumption of Compliance
There is an important Italian-specific element to be aware of.
The implementing decree provides that the application of a CCNL signed by the most representative trade union organizations constitutes a presumption of compliance with the principles of pay equality and transparency.
In practice: if you apply a recognized CCNL and respect the job classifications it provides, you are already in good shape. The collective bargaining agreement's classification system is considered gender-neutral, unless proven otherwise.
But be careful: this covers the job classification system, not individual pay decisions. If an employee is correctly classified but earns less than a colleague at the same level for non-objective reasons, the problem remains.
Art. 4, paragraph 1 – Government Act No. 379 (article still pending parliamentary approval) «The application of a national collective bargaining agreement signed by comparatively more representative trade union organizations at the national level [...] constitutes a presumption of compliance with the principles of pay equality and transparency [...] without prejudice to proof of the existence of discriminatory individual pay treatments»
What to Do to Avoid Penalties
We'll take care of it.
Pay transparency is no longer a choice. Failure to comply with the obligations exposes companies to very heavy penalties and a reversal of the burden of proof, requiring the company to defend itself proactively in court against uncapped compensation claims.
Exceeding the 5% gap threshold means risking immediate exclusion from public procurement, loss of financial incentives, and the obligation to initiate forced union negotiations to remedy the disparities.
To support you during this phase, in the coming weeks we will publish a complete operational guide with checklists and step-by-step instructions for each of these areas. If you want to receive it in advance, sign up here for our newsletter.
The Fall of the Taboo
This Directive breaks down the last great taboo in the workplace: money.
From 2026, pay stops being a secret whispered in the corridors and becomes the subject of open and necessary conversation.
The cultural shift is clear — it will no longer just be about numbers, but about starting to talk about money differently. It means educating people and making them aware of a world, that of their economic value, which until now has remained hidden beneath the surface.
This is where Financial Wellbeing comes into play.
It is not just about complying with a regulation, but about transforming transparency into a pillar of company culture. At Weltis we help companies manage this transition, bringing financial competence and awareness to where a taboo once stood.
If you want to understand how to implement this pillar in your organization and have everything ready before the conversations begin, let's talk.
📌 Quick Summary for Those in a Hurry
From June 7, 2026, all Italian companies will be required to comply with the pay transparency obligations set out in EU Directive 2023/970.
Job listings will need to state the salary or pay range for the position. It will no longer be possible to ask candidates what they currently earn.
Every employee will be able to request information on the average pay levels of their professional category, broken down by gender. The company will have 60 days to respond.
Companies with at least 100 employees will need to periodically report the gender pay gap. The data will be public and comparable with competitors.
If the gap exceeds 5% in any category and is not justified by objective criteria, a joint assessment with employee representatives becomes mandatory.
Contractual pay secrecy clauses will be prohibited by law.
The application of a recognized CCNL constitutes a presumption of compliance, but does not cover discriminatory individual pay decisions.
Preparation requires: pay audit, recruiting review, removal of secrecy clauses, definition of transparent criteria, structured response system, proactive internal communication.
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