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Dutch organisations are well aware of the European Pay Transparency Directive (EUPTD), but implementation lags behind. This is according to Highberg's research among 112 European organisations with more than 250 employees.
The benchmark shows that 55% of HR and Compensation & Benefits professionals are now well acquainted with the directive, 36% fairly familiar, 8% have heard of it and 1% are not familiar. Although 80% of organisations have now drawn up an action plan, around 47% are still in the preparation phase and only a third (32%) have actually started implementation.
The EUPTD requires employers to disclose pay structures, regularly report the gender pay gap and conduct a joint pay review with employee representatives in case of an unjustified difference of more than 5%. EU member states must incorporate the directive into national law by 1 January 2027; large employers must report for the first time in June 2027.
This illustrates a clear gap between awareness and action. Many organisations still underestimate the structural and cultural changes required to comply with the directive. In particular, transparent communication of remuneration information and reporting appear to be the biggest challenges.
These challenges also translate to the level of compliance. On average, organisations rate themselves as fully compliant with only 21% of the directive's articles. The remaining provisions are rated as 'partially compliant' (39%) or 'not yet compliant' (40%). Especially the articles on reporting and transparent communication (articles 7, 8 and 9) are perceived as complex, 67% of the provisions are considered challenging.
Organisations' concerns are clear, but there are also opportunities. According to the survey, reputational damage (68%) and legal risks (64%) are the biggest concerns in case of non-compliance. At the same time, 72% of organisations see the directive as an opportunity to increase internal trust. 63% therefore see the introduction as an opportunity to strengthen equal pay for equal work. Although the directive is often seen as an obligation, it actually acts as a catalyst for positive change. After all, transparency increases trust within organisations and enhances their reputation and ability to attract talent.
As a result, remuneration policies are under pressure. Half of the organisations expect that they will have to adjust their policies to comply with the new rules, especially in terms of basic and variable pay. It also appears that 45% of organisations regularly deviate from existing remuneration frameworks, for example by offering higher entry-level salaries for scarce positions. Such deviations can eventually lead to inequality within the organisation, according to Highberg.
"Many organisations are still at the beginning of their journey towards full compliance with the EU directive," says Gido van Puijenbroek, Managing Partner People Analytics & Research at Highberg. "To become truly compliant, it is important for organisations to start mapping pay gaps and setting up transparent job evaluation. It also helps to review remuneration policies, implement reporting structures and clearly inform employees about remuneration processes. Organisations that start these steps early and conduct internal testing have enough time to make improvements before official reporting begins. In this way, they can not only mitigate risks, but also increase internal trust and foster a culture of equal pay for equal work."
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