What Does the EU Pay Transparency Directive Mean for Recruiters? The EU Pay Transparency Directive came into force on 7 June 2026. If you place candidates into roles based in EU countries, here is what you are now legally required to do differently.
What is the EU Pay Transparency Directive?
The EU Pay Transparency Directive (2023/970) is legislation that requires employers and recruiters to be open about pay at the point of hiring. It applies across all EU member states from 7 June 2026.
It does not apply to UK roles. But if you are a UK-based recruiter working on any role where the candidate will be employed in an EU country, the directive applies to that hiring process.
Does the EU Pay Transparency Directive apply to UK recruiters?
Yes, if the role is EU-based.
The legislation is tied to where the role is located, not where the recruiter or agency sits. A recruiter based in London placing a candidate into a role in Dublin, Amsterdam or Berlin is required to follow the directive for that placement.
What are recruiters required to do under the directive?
There are two core requirements that affect day-to-day recruitment practice.
Salary must be disclosed before the first interview.
The salary or salary range must be shared with candidates before they attend their first interview. The simplest way to meet this requirement is to include the range in the job ad. In some countries, including Ireland and Italy, including it in the ad is mandatory rather than optional.
You cannot wait until offer stage. You cannot keep it vague.
You cannot ask candidates what they currently earn.
The ban on salary history questions covers every point of contact from the first conversation through to the point of offer. That includes phone calls, emails and intake calls.
You can ask candidates what salary they are looking for. You cannot ask what they are currently being paid, what they earned previously, or anything that ties an offer to their history rather than the value of the role.
Can you write “competitive salary” in a job ad for an EU role?
No. “Competitive salary”, “DOE” (depending on experience), and similarly vague language do not satisfy the directive’s requirements. A genuine salary range, stated in the currency of the country the role is based in, is what the directive requires.
A range so wide it gives candidates no useful information is also unlikely to hold up to scrutiny.
What counts as a compliant salary range in a job ad?
A specific minimum and maximum tied to the role. For example: €58,000 to €72,000 per year, depending on experience.
Bonus and benefits can be listed separately, but the base salary range must be present and genuine.
Which EU countries require the salary range in the job ad itself?
Requirements vary by country. As of June 2026:
Ireland requires the salary range in the job ad.
Italy requires pay information in the job posting, not just disclosed pre-interview.
Netherlands requires disclosure before the first interview. A new national law is expected in January 2027 that may bring further requirements.
Germany has national legislation still pending despite the directive being in force. The directive baseline applies.
France has delayed national law adoption. The directive baseline applies.
Poland allows flexibility on timing, but salary must be disclosed by offer stage at the latest.
The safest approach for any EU role is to include the salary range in the job ad regardless of country. It meets the requirements of the strictest markets and removes the risk of missing a pre-interview disclosure step.
What should you do if a client refuses to give a salary range?
Push back. Explain that vague pay language is no longer legally acceptable for EU roles. If the client has not yet decided on a range, work with them to define one before the role goes live.
A role that is advertised without a salary range in a country that requires one is non-compliant from day one.
Frame the conversation around protecting the client from legal exposure. Many UK-based hiring managers are not yet aware that this has changed. Briefing them is part of your role on any EU placement.
Can you use a candidate’s salary history to set the offer if they volunteer it?
No. Even if a candidate tells you what they currently earn without being asked, that figure should not be used to anchor the offer. The offer should reflect where the candidate sits within the role’s salary range, not what they happened to disclose.
Passing a candidate’s current salary to a client and suggesting it be used as a negotiating tool would breach the spirit of the directive even if the candidate raised it first.
What is the process for a compliant EU hire?
- Obtain a confirmed salary range from the client before the role is advertised.
- Include the range in the job ad, stated in local currency, with no vague language.
- When speaking to candidates, ask about their salary expectations. Do not ask what they currently earn.
- If the range was not in the job ad for any reason, confirm it with the candidate in writing before their first interview.
- Ensure the final offer sits within the range that was disclosed.
Where can I find the full guide?
The Marketing Junction has published a practical guide for recruitment teams covering job ad requirements, candidate conversation scripts, a country-by-country breakdown, and a compliance checklist for every EU role.
Download the EU Pay Transparency guide here
This post reflects the EU Pay Transparency Directive (2023/970) as in force from June 2026. Country-level national legislation is still developing in some markets. For legal advice specific to a particular jurisdiction, consult qualified employment counsel.