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June 7, 2026, marks the deadline by which the European Pay Transparency Directive was to be transposed into the national law of Member States. For thousands of Belgian companies, the rules are changing: salary ranges in job postings, an enhanced right to information for employees, and mandatory reporting on the gender pay gap. This guide explains what the directive practically imposes, to whom, according to what timeline, and why the real challenge is not legal, but organizational.
Pay transparency refers to an organization's ability to make the mechanisms that determine employee remuneration visible and understandable. It does not mean publishing everyone's salary on the intranet. It is something much more demanding: being able to explain, at every level of the company, why a specific position is paid at a certain level, according to what criteria, and how these criteria are applied consistently and non-discriminatorily.
Pay transparency covers three distinct dimensions:
Why did the European Union decide to legislate? Because voluntary approaches failed. The EU gender pay gap narrowed from 16.2% to 11.1% between 2011 and 2024—thirteen years to achieve a five-percentage-point improvement. Yet, the principle of equal pay has been enshrined in European law since the Treaty of Rome in 1957. Since recommendations were not enough, Directive 2023/970 establishes binding obligations.
Directive (EU) 2023/970 of the European Parliament and of the Council, adopted on May 10, 2023, in Strasbourg, aims to strengthen the application of the principle of equal pay for equal work or work of equal value. It is structured around four operational pillars.
Companies will have to state the starting salary or its range in job postings, or at the latest, prior to the first interview. The practice of "salary dependent on profile" disappears. It will also be forbidden to ask candidates about their salary history in previous positions.
This represents a profound cultural shift for many Belgian recruiters. Salary negotiation can no longer rely on information asymmetry.
All employers, regardless of their size, must formalize and make accessible the objective criteria used to set salaries: classification grids, levels of responsibility, required skills, and seniority. An employee can request to know the average pay level, broken down by gender, for the category of workers performing the same work or work of equal value. The employer must respond.
This right to information transforms the individual relationship with salary. An employee who feels underpaid will now have the means to verify and demonstrate it.
This is the most structurally impactful obligation for larger companies. Companies with between 100 and 250 employees must provide a gender pay gap report every three years. Those with more than 250 employees must do so annually.
This report must include the mean and median gender pay gap, the gap in variable pay components, and the proportion of workers in each salary band.
If the gender pay gap exceeds 5% without any objective justification, the employer is required to take corrective measures. This 5% threshold is the legal trigger for a mandatory obligation to act, not a mere recommendation.
This is the most radical shift in the balance of power. The burden of proof is reversed: in the event of a dispute, it is the employer who must demonstrate the absence of discrimination, rather than the worker having to prove they are a victim.
Sanctions for non-compliance are significant. The directive requires Member States to provide for "effective, proportionate, and dissuasive" penalties, the amounts of which will be defined by Belgian national transposition. Added to this is the possibility of exclusion from public tenders and the obligation of full compensation for victims, with no upper limit.
Upon transposition of the directive into Belgian law, all companies without exception are affected by recruitment transparency obligations and the employees' right to information. There is no size threshold for these two aspects.
⚠️ Important Note on Belgium: As of today, the transposition of the directive into Belgian law is partial and delayed. It was implemented for the French-speaking public sector via a decree from the Wallonia-Brussels Federation (adopted on May 16, 2024, and in force since January 1, 2025) as well as for the Flemish public sector via a Flemish government decree scheduled to enter into force on June 7, 2026. For the federal private sector, no text has been adopted yet: discussions are ongoing within the National Labour Council, and the Belgian government officially requested a six-month extension from the European Commission on June 1, 2026. However, in the absence of formal transposition, private sector workers will still be able to rely on the direct effect of the directive starting June 7, 2026.
For Belgian HR managers, part of the groundwork has already been laid. The Law of April 22, 2012, already requires companies with at least 50 workers to submit an analysis report on their pay structure to the Works Council or union delegation every two years. Companies with 100 workers or more use a full form; those between 50 and 100 use an abbreviated one.
The European Directive goes further: it requires external publication of this data, rather than just internal communication to staff representatives. The difference is substantial.
This is where most companies will hit an uncomfortable reality. Meeting the obligations of the directive requires having a structured, documented, and defensible pay policy. For many companies with 200 to 600 employees, this is simply not the case.
Salaries have often been built organically over time: individual negotiations, profile-based adjustments, informal seniority, and recruitment pressures on certain roles. The result is a compensation architecture that no one truly controls.
Publishing data on such an architecture means exposing oneself.
Prepare for these questions. They are coming.
If you do not have a documented, consistent answer to these four questions, now is the time to work on them.
Legal compliance is the floor, not the ceiling.
Companies that treat pay transparency as a strategic lever rather than an administrative burden achieve measurable results in engagement and retention. The mechanics are simple: transparency reduces uncertainty, and uncertainty is a major driver of disengagement.
According to an analysis by Glassdoor, 67% of candidates consider pay transparency to be an important factor when evaluating a potential employer. In a job market where talent attraction is a matter of survival for many companies, this is a signal hard to ignore.
67% of candidates consider pay transparency to be an important factor when evaluating a potential employer.
We must call out the risk. Enforced transparency without proper preparation can create more tension than it resolves. Discovering a pay gap without an explanation fuels distrust. The directive creates an obligation of result. The path to get there is a managerial decision.
Pay transparency is not just an HR compliance topic reserved for lawyers and payroll managers. It is an organizational diagnostic. It forces an answer to a simple, and often uncomfortable, question: do you really know how salaries are structured in your company? And can you explain it to your employees?
Three priority actions for Belgian HR managers as of early June 2026:
This is precisely where eBloom can help you: by regularly measuring the perception of fairness and transparency within your teams, you gain a leading indicator before the directive forces your hand. Internal data is your best steering tool before it becomes an external obligation.
From HR digitalization to AI integration and new employee expectations, the human resources sector is rapidly changing. Based on responses from over 450 Belgian companies, our report gives you a head start to prepare your teams and strategy for the realities of tomorrow.
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