CHRO Association concluded its six-part EU Pay Transparency Virtual Masterclass series with a discussion on the evolving legal landscape, practical implementation challenges and the future of global pay transparency. Here’s what we covered in session 6.
The legal picture: David Fortney of Fortney & Scott gave a legal update on national implementation of the EU Pay Transparency Directive.
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Activity will accelerate across member states in the coming months.
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Expect a complex, uneven compliance environment as countries implement at different speeds.
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Employers should keep monitoring each country rather than wait for full legal certainty—and prepare for employee pay-information requests, even in jurisdictions that haven’t fully implemented the Directive yet.
The operational lift: Don Lustenberger of DCI Consulting examined the operational work required to respond to those requests. Employers need:
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Clearly defined worker categories.
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Current job descriptions.
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A defensible approach to evaluating work based on skills, effort, responsibility and working conditions.
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Companies should also establish a consistent workflow for handling requests, plus proactive pay-gap assessments while there’s still time to fix issues before reporting begins.
On vendors: Pick tools carefully. Any methodology should align with the Directive, use reliable data and produce results the organization can explain and defend. Technology can flag patterns and prioritize risk, but it can’t replace legal review or judgment.
One company’s playbook: Jen Hupp, VP of HR, Enterprise Total Rewards at Avery Dennison, shared how her team manages pay transparency across 50+ countries. The company’s model centers on monitoring legal and market developments, establishing global principles while adapting to local requirements and training managers with practical resources. She also highlighted the importance of coordination among Total Rewards, HR, legal, works councils and employee resource groups.
Four essential priorities for employers:
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Act now based on your organization’s current data, job architecture and readiness.
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Define the organization’s pay philosophy and communicate it clearly.
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Treat pay transparency as a cross-functional business initiative.
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Train managers to explain pay decisions and respond confidently to employees.
What’s next: CHRO Association plans to reconvene members in early 2027 as more countries finish implementation and employer practices continue to develop.
