Pay transparency ante Portas: The benchmark is shifting

The EU Pay Transparency Directive has reached companies. Even if it has not yet been implemented into national law in Germany, there is little doubt about the need for action.

The driver here is not just the (upcoming) regulatory obligation, but primarily the already foreseeable increase in transparency – externally, but above all internally. If you want to be positioned for the future, you need a professional, consistent compensation system. And we are currently working hard on this in many places.
At the same time, the uncertainty as to which path the legislature will ultimately take creates a special mixed situation: the more intensively companies deal with the requirements, the more open detailed questions become apparent. This means: Preoccupation with equal pay is increasing, as is a certain level of uncertainty.

From the pioneering debate to market movements

The Kienbaum Equal Pay Readiness Check shows, among other things, how much the topic is becoming more relevant. More than 900 companies have taken part since March 2025. At first glance, the current evaluation appears to show a decline in the average level of maturity of companies.

In reality, however, the development is less a reflection of a deterioration and more the result of broader market participation. On the one hand, many companies are only now systematically dealing with equal pay and pay transparency. On the other hand, even advanced organizations have recently assessed their position more critically – not least due to the existing regulatory uncertainties.

The more knowledge, the more detailed questions

Examples from consulting practice illustrate what concerns those responsible for projects. Typical questions at the operational level include:

• What data needs to be exported from the Human Resources Information System (HRIS)?
• How can work of equal value be defined in a resilient way?
• Which comparison groups are appropriate?

However, this often leads to bottlenecks in implementation: As long as detailed national regulations are missing, many of these questions cannot be answered conclusively. Some companies are therefore pragmatically guided by the EU Pay Transparency Directive, the report of the expert commission on the low-bureaucratic implementation of pay transparency, existing case law and experiences from other European countries.

Advanced organizations in particular are experiencing an increasing relativization of their own level of maturity. Against this background, the Readiness Check no longer speaks of “equal pay professionals” but of “advanced people”. Not because the preparation is inadequate – but because the reference standard is moving and shifting.
The more intensively companies look at the requirements of future pay transparency legislation, the more open detailed questions become apparent.

Three types – and what changes in practice

The current evaluation of the readiness check continues to differentiate between three levels of maturity:

1. Waiting optimists: more companies on hold

The share of this category is increasing. This is initially surprising as the implementation deadline is approaching. However, upon closer inspection, the development is understandable: many companies are only now prioritizing the issue, often triggered by internal inquiries or increasing attention. At the same time, the lack of national legislation encourages some organizations to adopt a wait-and-see attitude. From the experts’ point of view, optimism is helpful – but what is crucial is to actively use the time gained to deal with it in a well-founded manner.

2. Number acrobats: strong in data, not automatically capable of providing information

Companies in this growing group have reliable salary and personnel data and are investing in the systematic documentation of compensation decisions. However, implementation shows that data alone does not create the ability to report or provide information. Challenges arise particularly when defining work of equal value and when converting analytical results into concrete measures. There is therefore sometimes a gap between data availability and actual readiness for implementation.

3. Advanced: well set up, but not “finished” yet

The more advanced have established strategies, structures and processes. Roadmaps have been defined, initial analyzes have been carried out, roles have been clarified. At the same time, these organizations clearly recognize their open issues – especially in terms of governance, communication (internal and external) and co-determination (i.e. involvement of works councils and stakeholders). The lack of detailed legal clarity also makes the next step difficult in many places. Nevertheless, it is clear that this group in particular professionalizes their systems particularly consistently.

In demand: scoping, scaling and tools

In view of this, the levels of maturity described also bring with them different challenges for those affected. Accordingly, three specific topic clusters have recently emerged in consultations with companies that are in increasing demand depending on the level of maturity and initial situation.

1. Pragmatisches Scoping

Companies want to know: Where are we really – and what is the next sensible step? Structured assessments of the situation are required, often with traffic light logic, which confirm strengths, make gaps transparent and enable prioritized roadmaps. Worth mentioning: Advanced users also use scoping to validate assumptions and uncover blind spots.

2. Scaling across organizational units

Larger companies in particular with multiple legal entities or tariff worlds develop scalable process models. Typically, a clearly defined organizational unit – such as the parent company or a pilot subsidiary – is first made “policy-fit” (with external support). The process model developed there is then rolled out in a structured manner to other units in the company. This is less about the one-off analysis project and more about repeatable systems. To this end, pilot projects are converted into implementable playbooks – with clear definitions, roles and process logic.

3. Digital support as an efficiency and quality lever

Digital solutions are becoming increasingly important. Aids such as pay equity tools that consulting companies offer can help you consistently repeat pay analyses, fulfill information obligations and systematically document evaluation logic (e.g. around work of equal value). This turns selective analysis into a sustainable process.

Set guidelines for 2026

Despite the lack of clarity surrounding the specific implementation of the EU directive into local law, the following three steps are recommended in order to prepare as best as possible.

1. Identify and address risks early on

It’s not about perfect analysis in the first step, but about transparency. Initial evaluations quickly show where structural weak points lie – for example in terms of
Data quality (is the data internally consistent or are there errors lurking everywhere?), evaluation logic (is the definition of work of equal value missing or is it perhaps questionable?) or processes (are the structures and processes in the company conducive or hindering equal pay?).

2. Define work of equal value in a methodically clear manner

Defining equal work is the biggest challenge for many companies. This is where the quality of the employer’s argumentation comes into play. Without reliable evaluation logic – often in the form of analytical grading – there is no benchmark. It is precisely at this point that many people falter and those who are more advanced sharpen their skills.

3. Consistently operationalize implementation

Roadmaps alone are not enough. Roles must be defined, decisions documented, stakeholders involved and communication concepts prepared. The goal is a repeatable, scalable system – not a one-off exercise.

Conclusion

Equal pay has become widespread. However, as the conflict grows, so does the uncertainty – even among advanced companies. This is not a step backwards, but rather an expression of increasing professionalization. This means opportunities for HR: Regulatory pressure can result in a structural increase in quality – for compensation systems, processes and trust in fairness. Regardless of the timing of national implementation, the following applies: anyone who acts systematically now not only creates compliance, but also positions remuneration strategically for the future.