Salary transparency in Europe is not one rule but a patchwork of national traditions that the EU is now trying to align. Austria has required pay information in job ads since 2011, Spain obliges every company to keep a pay register, France publishes an equality index for every company with 50+ employees, and in Norway anyone can look up a neighbour’s taxable income. Meanwhile, in countries such as Germany or Italy, most job ads still say nothing about pay.
The EU Pay Transparency Directive (2023/970) sets common minimum rules: pay information for candidates before the interview, a ban on pay history questions, employee information rights and gender pay gap reporting. Its transposition deadline was 7 June 2026, but its obligations apply only through national laws once transposed, and countries may keep rules that go further. For HR teams that hire in several countries, that means managing the existing national rules and the new ones at the same time.
This guide compares the main European countries, shows what TalentUp job ads data reveals about salary disclosure by job family, and sets out a strategy for multi-country employers.
Key takeaways
- Before the Directive, only a few countries required pay in job ads: Austria (since 2011), Lithuania (since 2019) and, for the pre-interview stage, Poland (since December 2025).
- Pay reporting is far more common: Spain, France, Italy, Germany, Austria, Denmark, Ireland and the UK all had their own gender pay regimes, with different thresholds and formats.
- The Nordic countries add a cultural layer: public tax records make individual incomes visible in Norway, Finland and, partly, Sweden.
- TalentUp data shows the legal effect: about 58% of Austrian job ads state pay in 2026, against about 22% in Germany, and the gap holds in HR, IT, sales and finance.
- Multi-country employers should design to the strictest standard they face, on one common job architecture, rather than country by country.
Why Salary Transparency in Europe Is So Uneven
Pay transparency in Europe grew out of three different traditions, which explains why the rules look so different from one border to the next:
- Job ad rules, which give candidates pay information before they apply. Austria is the classic example.
- Gender pay reporting, which obliges employers to measure and disclose pay gaps, internally or publicly. This is the most widespread model: Spain, France, Germany, Italy, Ireland, Denmark and the UK all use a version of it.
- Public income records, a Nordic tradition in which tax data, rather than employer reporting, makes pay visible.
Collective bargaining adds a fourth, informal layer. Where most jobs are covered by a collective agreement with published pay scales, as in Austria or Germany, a large part of pay is already known even when the job ad is silent. Where pay is set individually, the job ad is often the only place a candidate could learn it.
Collective agreements do not meet the Directive’s equal-value test automatically, though. Christine Aumayr-Pintar, research manager at Eurofound, the EU agency for living and working conditions, presented its research on how social partners can make pay scales in collective agreements objective and gender neutral:
CA
Christine Aumayr-PintarResearch Manager, Eurofound
Their role is important, but our findings show that reviewing job classifications and correcting unjustified pay gaps within collective agreements is often a lengthy process. Wage drift, individual negotiations and the absence of pay scales can make this task even more difficult.
The EU Directive does not erase these traditions. It sets a floor that every member state must reach, and lets each country keep what already goes further.
Country Comparison: Salary Transparency Laws in Europe
The table summarises the main rules that existed in each country before or alongside the transposition of the Directive. It is an overview, not legal advice: thresholds and details change, so check the current national law. For the transposition status of the Directive itself, see our guide to the 2026 EU pay transparency law.
| Country |
Pay in job ads |
Pay reporting and audits |
Employee access to pay data |
| Austria |
Required since 2011: minimum pay under the collective agreement or law, plus any willingness to pay more |
Internal income report every 2 years for employers with more than 150 employees |
Income report shared with the works council or made accessible to staff |
| Lithuania |
Required since 2019: base wage or wage range in all job ads |
Gender-disaggregated pay data for employee representatives at employers with 20+ employees |
Through employee representatives |
| Poland |
Starting pay or range before the first interview since 24 December 2025 (not necessarily in the ad) |
Planned under the Directive |
Pay history questions banned since December 2025 |
| Spain |
Not required |
Pay register for all companies (since 2021); pay audit for companies that must have an equality plan (50+ employees) |
Via workers’ representatives; otherwise percentage gaps by gender |
| France |
Not required |
Index de l’égalité professionnelle: companies with 50+ employees publish a score out of 100 every year by 1 March |
Index published; corrective measures below 75 points |
| Germany |
Not required |
Pay equality reports for employers with more than 500 employees that must publish a management report |
Individual right to information at employers with more than 200 employees (since 2017) |
| Italy |
Not required |
Biennial report on male and female staff for companies with more than 50 employees (threshold lowered from 100 in 2021) |
Shared with union representatives and regional equality advisers |
| Denmark |
Not required |
Gender-segregated pay statistics for companies with at least 35 employees and 10 men and 10 women in the same job function |
Statistics presented to employees, or an equal pay report agreed with them |
| Ireland |
Not required |
Public gender pay gap reports: 250+ employees from 2022, 150+ from 2024, 50+ from 2025 |
Reports published |
| United Kingdom (outside the EU) |
Not required |
Public gender pay gap reports for employers with 250+ employees since 2017 |
Reports published on a government portal |
| Norway (outside the EU) |
Not required |
Not the main lever |
Public tax lists: net income, wealth and tax paid of every taxpayer |
| Finland |
Not required |
Not the main lever |
Public tax information published every November |
| Sweden |
Not required |
Not the main lever |
Total earned income public on request (employment income separately only up to income year 2022) |
Three groups emerge. Austria and Lithuania already behave the way the Directive intends for recruitment. Spain, France, Italy, Ireland and the UK have mature reporting cultures but little transparency in job ads. Germany sits in between: a right to information exists, but only in larger companies, and job ads rarely mention pay.
Job Ad Pioneers: Austria, Lithuania and Poland
Austria: minimum pay in every job ad since 2011
Since March 2011, Austria’s Equal Treatment Act (Gleichbehandlungsgesetz, § 9) has required employers and recruitment agencies to state in job ads the minimum pay that applies to the position under the collective agreement or law, and to say whether they are willing to pay more. Ignoring the rule leads first to a warning and then to a fine. The obligation is light by design: the minimum is often the collective agreement scale rather than the real budget, which is why many Austrian ads read “minimum €3,200 gross per month, with willingness to pay above this depending on experience”.
Even so, the rule changed behaviour. As the data section below shows, Austrian job ads state pay far more often than those of any neighbouring country. TalentUp’s pay transparency guide for Austria covers the national rules in detail.
Lithuania: wage ranges since 2019
Lithuania amended its Labour Code in 2019 so that job ads must state the proposed base monthly or hourly wage or wage range, excluding supplements and bonuses, on every channel used. According to figures.hr, Lithuania was also one of the first countries to fully transpose the Directive, with the new requirements effective from 7 June 2026. See our Lithuania pay transparency guide.
Poland: an early start on recruitment
Poland did not wait for the full transposition. Since 24 December 2025, the Labour Code has required employers to give candidates the starting pay or pay range before the first interview, to use gender-neutral job ads and titles, and not to ask about pay in current or previous jobs. Publishing the range in the ad is one way to comply, not an obligation. More in our Poland pay transparency guide.
Reporting Cultures: Spain, France, Germany, Italy and Beyond
Spain: pay registers and pay audits
Royal Decree 902/2020, in force since April 2021, requires every company, regardless of size, to keep a pay register with mean and median pay by sex and professional category, broken down by pay component. Companies that must have an equality plan (50 or more employees) also carry out a pay audit with a job evaluation and an action plan, and must justify in the register any gap of 25% or more in average pay between men and women. Spain’s rules are therefore close to the Directive’s reporting logic, even though job ads rarely mention pay. See our Spain pay transparency guide.
Having a pay register does not mean Spanish companies are used to talking about pay. Paz de la Iglesia, employment partner at A&O Shearman in Madrid, made the point in the firm’s cross-border analysis of the Directive:
Paz de la IglesiaEmployment Partner, A&O Shearman (Madrid)
In Spain, small and medium-sized enterprises and sectors with wider gender gaps – like industrial, healthcare, and services – will face the biggest adjustments. The idea of informing candidates and employees about pay practices is simply new territory for many.
France: the Index de l’égalité professionnelle
Since 2019–2020, companies with 50 or more employees in France have calculated and published a gender equality index every year by 1 March. It scores the company out of 100 on indicators such as the pay gap, pay rises and promotions. Below 75 points, the company must take corrective measures, and if it fails to improve over three years it can be fined up to 1% of its payroll. The Directive’s more granular reporting will change this model once France’s transposing law applies. See the France pay transparency guide.
Germany’s Pay Transparency Act (Entgelttransparenzgesetz) has given employees at employers with more than 200 employees the right to ask how their pay compares with that of colleagues of the other sex doing equal or equivalent work. Employers with more than 500 employees are encouraged to run internal pay audits, and those that must publish a management report also report on equal pay. The Directive will extend information rights to all employers, regardless of size. See the Germany pay transparency guide.
Italy, Denmark, Ireland and the UK
- Italy: companies with more than 50 employees submit a biennial report on male and female staff to the Ministry of Labour, covering recruitment, roles and pay. Italy is among the countries that transposed the Directive in June 2026, according to figures.hr and Euronews. See the Italy guide.
- Denmark: Statistics Denmark prepares gender-segregated pay statistics each year for companies with at least 35 employees and at least 10 men and 10 women in the same job function, which must be presented to employees. Companies can instead agree an equal pay report with their staff.
- Ireland: the Gender Pay Gap Information Act 2021 introduced public reporting of mean and median hourly pay gaps, bonus gaps and the share of staff receiving bonuses, phased in from 250+ employees (2022) to 50+ employees (2025).
- United Kingdom: outside the EU and not bound by the Directive, the UK has required employers with 250 or more employees to publish their gender pay gap every year since 2017.
The Nordic Model: Public Tax Records
The Nordic countries are often described as the most transparent in Europe, but the transparency comes from tax records rather than employers:
- Norway publishes searchable tax lists with the name, year of birth, net income, net wealth and tax paid of every taxpayer; they have been online since 2001 and searches require a verified login.
- Finland publishes public information on individual income taxes every November, and the tax administration shares data on high earners with the media.
- Sweden treats tax information as public records, which anyone can request from the Tax Agency. Since income year 2023, only total earned income is public, no longer employment income on its own.
This visibility shapes attitudes: talking about income is less taboo, and employees can roughly check what managers or peers earn. But tax lists show total annual income, not pay by role, and they say nothing about pay ranges for a vacancy. They do not replace the Directive’s employer obligations: Denmark and Finland, for example, are transposing it with laws targeting 2027, according to figures.hr.
What TalentUp Data Shows: Salary in Job Ads by Job Family
Do national rules change what employers actually publish? To find out, TalentUp analysed job ads published between January and September 2026 in seven countries, split by job family: HR, IT, sales and finance. The figures are minimum estimates of the share of ads that state a salary.
~58%
of job ads in Austria state pay
~22%
do in Germany, ~27% in Spain and ~17% in Italy
5x
more Austrian than German IT job ads state a salary (62.9% vs 12.2%)
Source: TalentUp job postings database, January–September 2026. Minimum estimates, see methodology below.
| Job family |
Austria |
Netherlands |
UK |
France |
Spain |
Germany |
Italy |
| HR |
62.5% |
54.2% |
64.7% |
26.1% |
18.8% |
27.4% |
17.6% |
| IT |
62.9% |
38.2% |
51.9% |
17.6% |
13.7% |
12.2% |
14.2% |
| Sales |
57.1% |
41.7% |
48.3% |
27.8% |
20.1% |
18.1% |
18.8% |
| Finance |
57.6% |
42.1% |
48.0% |
15.9% |
18.6% |
12.1% |
15.5% |
Share of job ads that state pay, by job family (stricter detection than the country totals; see methodology).
Three findings stand out:
- The law shows in the data. Austria is the only country in the sample with a long-standing duty to state pay in job ads, and it is the only one where every job family is above 55%. Germany shares the language, many employers and a collective bargaining culture with Austria, yet only 12–27% of its ads state pay. The gap is largest in IT: 62.9% in Austria against 12.2% in Germany.
- Without a legal duty, culture decides. The UK and the Netherlands reach around 50–58% of ads without any obligation to publish pay in the ad, while France, Spain, Germany and Italy stay around 17–27%. Many Austrian ads quote only the collective agreement minimum, so “states pay” does not always mean a realistic range, but the habit is established.
- IT and finance are the most secretive families. In most countries, IT or finance ads are the least likely to state pay, a pattern consistent with individually negotiated pay for specialist roles. HR ads are among the most transparent in Germany, the Netherlands and the UK, possibly because many HR and recruiter roles are advertised by staffing agencies, which often quote pay.
For HR teams, the lesson is that the Directive’s pre-interview duty will be a bigger change for IT and finance hiring in France, Spain, Germany and Italy than for HR roles in the UK or any role in Austria. For the share of ads with pay across all job families and ten countries, see our analysis of transparent salary job postings.
How the EU Directive Harmonises the Map
Once transposed, the Directive gives every EU country the same core toolkit. The table compares its minimum standard with examples of national rules that already existed:
| Obligation |
Directive minimum (once transposed) |
Existing national examples |
| Pay information for candidates |
Initial pay or range before the interview, in the ad or otherwise |
Austria and Lithuania require it in the ad; Poland before the first interview since December 2025 |
| Pay history questions |
Banned |
Banned in Poland since December 2025 |
| Employee right to information |
All employers, any size: own pay level and average pay by sex for the same work or work of equal value |
Germany: only at employers with more than 200 employees |
| Gender pay gap reporting |
250+ workers annually from 7 June 2027; 150–249 every 3 years from 7 June 2027; 100–149 every 3 years from 7 June 2031 |
France and Ireland from 50 employees, Italy above 50, Denmark from 35, Spain’s pay register for all companies |
| Gap remediation |
Joint pay assessment if an unexplained gap of 5% or more is not remedied within 6 months |
Spain: justification of gaps of 25% or more; France: corrective measures below 75 points |
| Pay secrecy |
Workers cannot be prevented from disclosing their pay for equal pay purposes |
Czechia banned pay secrecy clauses in June 2025 |
| Equal pay claims |
Burden of proof shifts to the employer |
Varies by country before transposition |
The result is convergence, not uniformity. Countries that already go further, such as Austria with its job ad rule or France and Ireland with lower reporting thresholds, can keep their rules, and transposing laws differ in detail. The timeline also varies: by September 2026, figures.hr and Euronews reported that only five member states (Italy, Lithuania, Malta, Slovakia and Greece) had fully transposed the Directive, with many others targeting 2027. For what the Directive requires in detail, see our complete guide to preparing for the EU Pay Transparency Directive.
Strategy for Multi-Country Employers
For a company hiring in five or ten European countries, managing each country separately quickly becomes unworkable. A more robust approach:
- Map obligations by country and keep the map live. List, for each country, the job ad rule, the reporting threshold, the reporting calendar and the transposition status. TalentUp’s country pay transparency guides are a starting point.
- Design to the strictest standard. Sharing a pay range before the first interview and never asking about pay history is already required in some countries and will be required in all EU countries once the Directive is transposed. A single group-wide rule is simpler than many local exceptions.
- Build one job architecture. Comparisons of “work of equal value” need a consistent way to evaluate jobs on skills, effort, responsibility and working conditions. A common framework across countries makes local reports consistent and defensible.
- Respect local pay conventions. Austrian ads quote monthly gross pay and the collective agreement minimum, Spain and Italy often spread annual pay over 13 or 14 instalments, the UK quotes annual salaries. Use one policy with country templates, as described in our guide to transparent salary job postings.
- Reuse your reporting data. Spain’s pay register, France’s index, Ireland’s and the UK’s gender pay gap reports and Italy’s biennial report draw on the same payroll data. Build one dataset by sex, job category and pay component and generate each national report from it.
- Benchmark ranges on local market data. Published ranges are compared with the market immediately. Anchor them in current data for each country, for example with the free pay transparency salary benchmark; our article on salary benchmarking for EU pay transparency compliance explains how.
- Prepare managers for different cultures. In Norway an open conversation about pay is normal; in other countries it can feel intrusive. Train managers to explain how pay is set, and audit internal equity first, as discussed in Can Pay Transparency Backfire? and market salaries vs. internal equity.
Decide also how far to go beyond the legal minimum. Some employers publish ranges in every ad across Europe as an employer-branding choice; others share them only before the interview where the law requires it. Our article on how much pay information to share helps you choose.
The bottom line: salary transparency in Europe has always depended on where you look: job ads in Austria, pay registers in Spain, an equality index in France, tax lists in Norway. The EU Directive raises the floor for everyone, but national rules, transposition timelines and cultural habits will keep differing for years. Multi-country employers that set one strict standard, on one job architecture, backed by local market data, will handle that diversity far better than those that react country by country.
Sources