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How to prepare for the EU Pay Transparency Directive – Including the Swiss Perspective

With the EU Pay Transparency Directive taking effect on 7 June 2026, organizations will face significant changes in how they structure compensation, conduct hiring, and manage employee information. While focused on EU Member States, it also affects Swiss employers. This article outlines the key requirements and steps to prepare.


In brief

  • New pay transparency rules apply from 7 June 2026, with gender pay gap reporting for organizations with 150+ employees starting in 2027.
  • The Directive requires structured job architecture, gender‑neutral pay practices, and reliable HR/payroll data.
  • Swiss companies are affected in the EU Member States where they employ staff, and EU pay‑transparency standards are increasingly shaping expectations in the Swiss market.

As companies begin preparing for these upcoming changes, it is important to understand both the timing and the practical implications of the new requirements. Clarity on what will be expected enables organizations to start building the structures and processes needed for long‑term compliance.

Timeline at a Glance

  • The EU Pay Transparency Directive was approved in 2023.
  • All EU Member States must transpose the Directive into national legislation by 7 June 2026. Many Member States have not yet fully transposed the Directive and are expected to release draft legislation in early 2026.
  • Day one” employer obligations will apply from 7 June 2026, regardless of employer size. This includes pay transparency obligations towards applicants and employees.
  • Gender pay gap reporting begins in 2027 for employers with 150+ employees per Member State, using full‑year 2026 data.

Background: Pay Gaps and Growing Transparency Expectations

Gender pay disparities persist across Europe. In the EU, the gender pay gap remains around 12%, underscoring the need for stronger transparency and enforcement. Switzerland reports a median gap of 8.4% and a 14%  gap in middle and upper management roles. While Switzerland is not legally bound by the Directive, these figures contribute to rising pressure for clearer, more structured pay practices.

Given the strong economic ties between Switzerland and the EU, the Directive is quickly becoming a de facto standard for Swiss organizations operating internationally or employing EU based staff. Early alignment supports compliance, competitiveness, and evolving transparency expectations from employees.

Key Requirements of the EU Pay Transparency Directive

Implications for Swiss Companies

Although Switzerland is not a member of the European Union, the EU Pay Transparency Directive nevertheless affects many Swiss employers. Swiss companies must comply with the Directive whenever their activities involve employees and operations within the EU. This includes situations where Swiss based organizations employ workers located in EU Member States or recruit for positions based in the EU.

 

The Directive’s influence extends beyond strict legal requirements. Market trends in Switzerland indicate a growing shift toward greater pay transparency, driven in part by alignment with evolving EU practices. Swiss employees increasingly expect employers to demonstrate equal pay practices. While these expectations do not mirror formal transparency requirements, they nonetheless create pressure by effectively shifting the burden of proof onto employers.

 

At the corporate level, multinational Swiss headquarters are progressively adopting EU aligned frameworks to simplify compliance processes across jurisdictions and to ensure consistency across global operations, for example through harmonized job architecture.

 

Pay equity metrics are receiving heightened attention in governance reporting and stakeholder reviews, making early alignment with transparency obligations strategically advantageous. Swiss companies that proactively adapt to these developments position themselves more effectively in both regulatory and competitive contexts, demonstrating a commitment to fairness, transparency, and responsible business practices.
 

Recommended Actions for Organizations

With the implementation deadline approaching, affected employers are encouraged to begin preparations as early as possible. Effective readiness will require coordinated efforts across several key areas, starting with the foundational principles that guide pay‑related decisions. We outline the central starting points below:
 

1. Strengthening the Job Architecture and Pay Structures

A clear, objective job architecture is the backbone of compliance. This clarity supports transparency during hiring and provides a defensible basis for pay decisions. Employers should:

  • Review and modernize job families and levels.
  • Ensure job evaluation criteria are gender neutral and consistently applied.
  • Ensure appropriate salary bands are allocated to all functions.

2. Conduct a Pay Equity Analysis

Early diagnostics enable corrective action before reporting obligations begin. With roles clearly defined, organizations should:

  • Analyze pay gaps across comparable roles (categories of workers).
  • Identify unexplained gender pay gaps.
  • Prioritize areas with gaps above 5%, which may trigger future joint assessments.

3. Review Hiring, Promotion, and Performance Processes

Changes in hiring, promotion and performance reduce bias and enhance fairness in the employee lifecycle. To align with the Directive, employers should:

  • Eliminate the use of salary history information.
  • Document and communicate pay setting and progression criteria.
  • Ensure performance evaluations are structured and consistently applied.

4. Establish Cross Functional Governance

Reliable Human Resources (“HR”) and payroll data will be essential, especially for reporting purposes. Successful implementation requires collaboration between:

  • HR
  • Legal
  • Reward
  • Payroll
  • Local business leads

5. Prioritize Internal Communication and Training

Clear communication strengthens confidence and ensures smooth adoption of new processes. Transparency obligations introduce new expectations for managers and HR professionals. Organizations should:

  • Prepare managers to respond to pay related inquiries.
  • Train HR teams on new rights and reporting requirements.
  • Develop communication materials to support clarity and employee trust.

Summary

The EU Pay Transparency Directive, taking effect in June 2026, introduces extensive new obligations related to salary transparency, employee rights, and gender pay gap reporting. While not legally binding in Switzerland, the Directive affects Swiss employers with EU‑based staff and influences broader expectations in the Swiss labor market. Early alignment helps build fairness, compliance, and competitiveness in a shifting regulatory landscape.

To prepare, organizations should:

  • Strengthen job architecture
  • Conduct pay equity analysis
  • Update HR processes
  • Build cross functional governance
  • Prepare employees and managers through communication and training

Acknowledgments

We would like to thank Lukas Molkentin and Luisa Wexeler for their valuable contributions to this article.

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