If you work for a UK-headquartered company that also employs people in the EU, or you are weighing up an offer from one, the way salaries are advertised and discussed is shifting under your feet. The EU Pay Transparency Directive (Directive 2023/970) requires EU member states to transpose its provisions into national law by 7 June 2026, and although Westminster has not passed an equivalent statute, the rules will reach into UK operations through their European teams. That has real knock-on effects for what you can ask a recruiter, what a recruiter can ask you, and how much confidence you can place in the pay figure sitting at the top of an offer letter.

This piece covers what the directive gives workers and candidates in practice, how the UK's own legal framework compares, and the steps you can take now, before any domestic legislation catches up.

What changes on 7 June 2026 and why it matters beyond the EU

The EU Pay Transparency Directive is the European Commission's response to persistent gender pay gaps and the opacity that allows them to persist across hiring cycles. Under the directive's core obligations, employers operating in EU member states must: include a salary or pay range in every vacancy notice or share it with candidates before the first interview; stop asking candidates about their current or historical earnings; allow employees to request information on their own pay level and the average pay level, broken down by sex, for workers doing comparable work; and remove any contractual clauses that prevent workers from discussing pay with colleagues.

For UK workers, the direct legal effect is limited to those employed under an EU-country contract. The broader effect, however, runs through commercial logic: a London-based multinational that must publish pay bands for a role in Dublin or Amsterdam will find it increasingly awkward, and damaging to its employer brand, to keep the equivalent London or Manchester posting deliberately vague. Many are choosing a single transparent standard across all their markets rather than maintaining two parallel approaches that invite uncomfortable questions internally.

Where UK law currently stands

The UK's domestic framework already contains some building blocks, but they fall well short of the directive's ambitions. Under the Equality Act 2010 s.77, any contractual term that prohibits an employee from discussing pay with a colleague, for the purpose of finding out whether there is a pay difference connected to a protected characteristic, is unenforceable. In other words, pay-secrecy clauses of that type are already legally toothless in Great Britain, though many workers remain unaware of this protection.

Beyond that, the picture is patchy. The UK's gender pay gap reporting regulations, which sit under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, require employers with 250 or more employees to publish median and mean pay gap data each year, but they do not require employers to publish salary bands for individual roles or to give workers the right to compare their pay against colleagues in a structured way. The Office for National Statistics (ONS) Annual Survey of Hours and Earnings (ASHE) consistently records a median gender pay gap for full-time employees in the UK, and the gap widens when part-time workers are included, yet the reporting regulations alone have not closed it.

Westminster paused its pay transparency pilot for job applicants in May 2024 and has not set a domestic timetable to match the EU's June 2026 deadline. Advisory, Conciliation and Arbitration Service (ACAS) guidance encourages transparent pay practices as a route to reducing disputes, but ACAS guidance carries no statutory force. For now, a UK-only employer can still advertise a role with a phrase such as a competitive package and ask what you currently earn. That is the gap the directive, indirectly, is beginning to close from the outside.

What to do when a job advert hides the salary

A posting with no salary figure used to read as normal. From June 2026 onwards, within the EU, it signals non-compliance. If you spot an undisclosed salary on a posting from a multinational, that omission tells you something about how seriously the employer treats pay transparency as a value, not just a tick-box.

Some practical steps before investing time in an application:

• Ask for the pay range in your first message to the recruiter. If the role is open to EU-based candidates, the employer is required to share it before the interview stage anyway, so the request is entirely reasonable.
• If the recruiter declines, ask what the basis is for that. A phrase such as competitive salary is not a number, and a real salary negotiation needs a concrete anchor from both sides.
• Cross-check against external benchmarks: ONS ASHE data by occupation and sector, CIPD salary surveys, and verified pay data from company-review platforms all give you a reference point that is grounded in real reported figures rather than recruitment marketing.

If you are comparing several offers at once, this is the moment to put actual numbers alongside each one. A salary calculator that models net take-home pay across different gross figures and locations gives you a like-for-like comparison rather than a rough impression.

The salary-history question: you can decline

One of the directive's clearest rules is the ban on asking candidates what they currently earn or have earned previously. According to the European Commission, recruiters operating in EU member states will no longer be able to request pay history from candidates after transposition.

This matters because anchoring a new offer to your old salary is one of the most reliable mechanisms for carrying pay gaps from one job to the next. If you were underpaid in a previous role, because you were earlier in your career, in a lower-paying sector, or simply did not have the market data to negotiate effectively, repeating that number in a new process effectively bakes the gap in for another cycle. The CIPD's annual Reward Management Survey has noted for several years that salary benchmarking practices vary significantly across UK employers, and that workers who cannot access benchmark data are at a structural disadvantage in negotiation.

If you are applying for a role based in an EU country after the directive takes effect, you can decline a salary-history question and cite Directive 2023/970 directly. If you are applying for a UK-based role, the question remains legal, but you are under no obligation to answer it directly. Some neutral redirects that keep the process moving without ceding ground:

• Redirect to the role: ask what budget the employer has set for the position rather than confirming your current package.
• Anchor to the market: name an expectation range based on sector benchmarks for comparable roles, rather than your previous salary.
• Defer: explain that you are happy to discuss compensation in detail once both sides have confirmed the role is a strong fit.

None of these is evasive. They move the reference point from your personal pay history to the market, which is where it should always have been.

Already employed? You can ask where you sit in the pay structure

Under the directive, employees at EU-covered employers gain a specific right: per the European Commission's summary of Directive 2023/970, they can request in writing their individual pay level and the average pay level, broken down by sex, for workers doing the same job or work of equal value. The employer must respond.

For UK employees of a multinational, this right does not apply automatically under UK law. The Employment Rights Act 1996 does not currently include an equivalent individual pay-comparator right. However, if colleagues in your company's European offices begin requesting and receiving this information, internal conversations about consistency will follow. Maintaining two different transparency standards within a single organisation becomes operationally and culturally awkward, and some employers are choosing to extend voluntary transparency to their UK staff rather than manage the disparity.

ACAS notes that clear pay structures tend to reduce grievance rates and make it easier for managers to have honest conversations about progression. Whether or not your employer has EU operations, the following questions are worth putting to your manager or HR contact:

• What is the salary band for your current role, and what are the upper and lower boundaries?
• Where do you sit within that band, and what is the rationale for your placement?
• What does movement to the next band typically require, and over what timescale?

If the answers come back vague or inconsistent, that is itself useful data when you are deciding whether to stay, press for a clearer answer, or begin looking at the external market.

Cross-border roles: read the location field carefully

Remote and pan-European roles are where the rules become most consequential. If a posting is open to candidates in, say, Ireland, the Netherlands, and the UK, the EU-based candidates are covered by the directive once their country has transposed it. The UK candidate, at present, is not covered in the same statutory way.

Three patterns worth recognising when you read a pan-European job posting:

• A single pay band published across all locations. This signals that the employer has chosen to be transparent everywhere, not just where the law requires it.
• A pay range that appears only on the EU-country version of the advert. The range exists; it is just not on the UK version. You can reasonably ask why the UK posting does not carry the same information.
• Different ranges for different countries. This is often legitimate, reflecting differences in tax, statutory benefits, and local market rates, but it is worth asking how the bands were set before you accept a particular location's terms.

Verified employer reviews from current and former employees frequently surface the gap between what a company's careers page says about pay and what people actually receive. For cross-border roles in particular, reading reviews from staff in comparable roles across different countries can give you a clearer picture than any single job advert.

What to take away from all of this

The EU Pay Transparency Directive does not hand UK workers a new set of statutory rights at home. What it does is shift the centre of gravity in how multinational employers handle salary disclosure, what they are required to publish for EU-based hiring, and what candidates can request without the conversation becoming awkward. From 7 June 2026, a vague phrase such as competitive salary ceases to be a defensible answer for a substantial portion of the European job market, and that pressure does not stop at the Channel.

The UK framework, anchored in the Equality Act 2010 and supported by ACAS guidance, already protects your right to discuss pay with colleagues and requires larger employers to publish gender pay gap data. What it lacks, for now, is the proactive disclosure of salary bands at the point of hiring and an individual right to compare your pay against colleagues doing equivalent work. The High Pay Centre has argued consistently that voluntary transparency in the UK has not closed the gender pay gap at the pace that statutory requirements tend to achieve, and the CIPD's reward data suggests that pay-band visibility remains the exception rather than the norm across UK employers outside the largest organisations.

Three practical actions you can take this month, before any domestic legislation moves: request the pay range before you commit time to an interview process; stop sharing your previous salary unprompted, since the market rate for the role is a stronger negotiating anchor; and ask your current employer where you sit within your pay band and why. Each of those steps moves the conversation from guesswork to verified data, which is precisely what the directive is attempting to do for the broader European labour market.