EU Pay transparency requires more than a spreadsheet

The EU Pay Transparency Directive (2023/970) has several core obligations. Here are a few examples of how they map to Deel:

Article 5: Pre-employment transparency requires employers to provide salary ranges to candidates before the interview and introduces a ban on asking salary history. Deel offers a Compensation management module where you can create compensation bands. If you also use our HRIS, you can sync those bands to job postings automatically. Ranges are current and tied to the job profile, level, and location. With Engage, you can deliver training on the salary history ban for recruiters and hiring managers.

Article 6: Pay-setting and progression criteria require employers to make accessible to workers the criteria used to determine pay levels and pay progression. Criteria must be objective and gender-neutral. In Deel, our job architecture tool stores documented job families, levels, and job profiles. The compensation module links salary bands tied to those profiles. The job architecture is the defensible backbone.

Articles 9–10: Pay gap reporting and joint pay assessments require employers with 100+ workers to report gender pay gaps. If the adjusted gap exceeds 5% in any worker category and cannot be objectively justified, a joint pay assessment with worker representatives is required. Pay gap reports pull from real payroll data on Deel. No export, no reconciliation. Compensation audit trails document the criteria behind every pay increase decision, which is what you'll need if a joint pay assessment is triggered.

Deel provides the infrastructure and consulting services that help companies set themselves up for meeting these requirements. Compliance requires human judgment, legal expertise, and employer-side processes that no software replaces. We help you build the foundation. The decisions, criteria, and processes are yours.

Yes. The Directive sets a minimum standard, but each EU member state transposes it into national law with local variations. This matters because reporting thresholds, response timelines, penalty structures, and definitions of "remuneration" will differ by country. A company with employees in France, Germany, and the Netherlands may face three different sets of requirements once national laws are finalized.

Deel operates payroll and employment infrastructure across 150+ countries. As member states finalize their transposition laws, the platform's reporting and compliance workflows are designed to adapt to local requirements rather than treating the EU as a single jurisdiction.

Yes. Consulting services are available for organizations needing more than the tool infrastructure. They include:

• Pay equity audits with gap analysis and risk cartography
• Job architecture design with documented job families and levels
• Salary grid and band setting with non-discriminatory criteria
• Manager and HR training on compensation documentation and pay discussions
• HR data cleanup and reporting structure setup

These are delivered by Deel's consulting team and scoped as a separate engagement.

If you have employees in any EU Member State, yes. The obligation follows where the worker is located, not where the employer is incorporated. A US company with one employee in Germany is fully in scope. Even if you have zero EU workers today, structured compensation infrastructure is the foundation for fair, defensible pay decisions at any scale.

This is the question underneath all the others. The Directive defines it as work assessed to be of equal value using four criteria: skills, effort, responsibility, and working conditions. It's not just "same job title." A customer support job and a data entry job could be of equal value even though they're in different departments. In practice, the best defence is a structured, documented job evaluation methodology, applied consistently and auditable.

No, and this is where most companies underestimate the scope. The Directive covers all remuneration: base salary, bonuses, overtime pay, travel allowances, housing allowances, sick pay, occupational pensions, and any other cash or in-kind benefit. Variable pay has to be reported separately. If your base pay gap is small but your bonus gap is large, the report will show it.

Deel provides the infrastructure and consulting services that help companies set themselves up for meeting the Directive's requirements. Compliance requires human judgment, legal expertise, and employer-side processes that no software replaces. We help you build the foundation. The decisions, criteria, and processes are yours.