---
title: "Pay Transparency in Job Adverts: A Plain-English Primer for Founders"
description: "The EU Pay Transparency Directive moves the salary conversation into the advert, and most member states missed the June 2026 deadline. Here is how to build a defensible pay band before a candidate asks."
author: "Marcus Telle"
category: "Reading the Market"
date: 2026-10-18T07:25:00.733Z
canonical: "https://theartofpeople.io/blog/pay-transparency-job-adverts-founders-primer"
---

# Pay Transparency in Job Adverts: A Plain-English Primer for Founders

![the bottle, plastic, segregation](https://cdn.pixabay.com/photo/2020/05/04/10/31/the-bottle-5128607_1280.jpg?w=1200&q=75)

> The EU Pay Transparency Directive moves the salary conversation into the advert, and most member states missed the June 2026 deadline. Here is how to build a defensible pay band before a candidate asks.

Of all the awkward conversations in hiring, pay is the one founders defer longest, usually to the final call. Across much of Europe it is now moving somewhere considerably more public, which is the advertisement itself.

What follows is a primer, not legal advice. Each country writes its own version, several are still at the drafting stage, and anybody hiring across borders needs a local adviser in every one of them. The aim here is narrower: have your groundwork done before somebody at interview asks for a figure that nobody inside the company has yet agreed.

## What the Rules Are Actually Asking For

At bottom this is about stating what a job pays and standing behind the figure. The European directive on pay transparency, which member states had to convert into domestic law before 7 June 2026, turns that principle into specific duties.

The part that touches recruitment is Article 5. On [Remote Work Europe's reading of it](https://remoteworkeurope.eu/news/2026/eu-pay-transparency-directive-disclosures-2026), an applicant has to be given a starting salary or a starting range, derived from criteria that are objective and gender-neutral, ideally within the advertisement itself and at the very latest before the first interview takes place. Once a country has its implementing law running, this reaches every vacancy based there.

A second tier sits behind the advert. Organisations of [250 staff and upwards must report on pay gaps every year from 7 June 2027, working off 2026 figures](https://remoteworkeurope.eu/news/2026/eu-pay-transparency-directive-disclosures-2026), and smaller employers join the regime later. At ten people, that reporting belongs to somebody else for now. The advertising duty might already belong to you.

## How Far the Member States Have Got

The deadline arrived and most of the bloc missed it. Writing on 8 June 2026, the law firm Littler summarised the position:

> 
Comprehensive implementing legislation arrived on time in Slovakia, Malta and Italy. Elsewhere, the firm wrote, "most other member states did not." [Littler, 8 June 2026.](https://www.littler.com/news-analysis/asap/did-member-states-meet-deadline-status-implementation-eu-pay-transparency)

Three more countries, Lithuania, Poland and the Czech Republic, appear in the [same analysis](https://www.littler.com/news-analysis/asap/did-member-states-meet-deadline-status-implementation-eu-pay-transparency) as partially transposed, alongside a further set holding draft bills with no start date named. So this is a patchwork and not a starting gun. Recruiting into Italy means complying now. Recruiting somewhere still drafting buys you months, not years.

## Two National Laws, Read Side by Side

Summaries of the directive all sound alike. The national laws beneath them do not, and the gap is what a founder hiring in two countries needs to see. Take Poland and Malta, both of which have passed something and published the text.

Poland is the stricter of the two, and it names the advert first. An Act of 4 June 2025 amending the Labour Code, [published in the Journal of Laws on 23 June 2025 and in force six months after publication](https://api.sejm.gov.pl/eli/acts/DU/2025/807/text.pdf), gives an applicant the right to the starting pay or the pay range, set on objective and gender-neutral criteria, together with the relevant collective agreement or pay rules. The employer must supply it in writing or electronically, early enough to be read: in the advertisement, or before the interview if there was none or it was omitted, or before employment begins if neither applied. No headcount threshold appears anywhere in it.

Malta arrives at the same destination by a gentler road. Legal Notice 173 of 2026, gazetted on 5 June 2026, gives applicants a right to [the initial pay or its range on objective, gender-neutral criteria, plus the relevant collective agreement provisions, provided so as to ensure an informed and transparent negotiation on pay before the recruitment process concludes](https://legislation.mt/eli/ln/2026/173/eng). Read that timing carefully: this is not an advertising duty at all. The instrument itself names no commencement date, so anyone quoting you a precise one is quoting a law firm rather than the law.

Behind both sits the reporting regime. The European Commission's own guidance confirms the [7 June 2026 transposition deadline, limits pay reporting to employers with at least 100 workers, and phases it in: yearly from June 2027 for 250 workers and above, every three years from June 2027 for 150 to 249, and every three years from June 2031 for 100 to 149](https://commission.europa.eu/document/download/828ecf2a-e13d-4346-bdca-7eccbbfe28d3_en?filename=FAQs%20on%20the%20pay%20transparency%20Directive%20%28EU%29_2023_970.pdf).

And the United Kingdom? There is no duty to publish pay in a job advert. The statutory rules for employment agencies treat it as optional, requiring only that where [the rate of pay is included, the advert must also carry the nature of the job, its location, minimum experience levels and any training needed](https://www.gov.uk/employment-agencies-and-businesses/job-advertisements). British founders are therefore choosing, not complying, which makes the rest of this article a question of judgement rather than of paperwork.

## The Order of Work

None of what follows requires an HR function. It requires an afternoon.

- **Settle the role and the level.** Put down what this job covers, what it deliberately excludes, and how senior the person needs to be. Until the level is fixed, no range can mean anything, which is why [writing the description properly](/how-to-write-a-job-description-uk) comes before the number.

- **Construct the band.** Fix a floor and a ceiling for that level from market data and from what comparable people in your own company already take home. Record the reasoning as you go, since objective criteria is precisely what the directive asks you to be able to produce.

- **Publish it.** Either in the advertisement or directly to the candidate before you first speak. An honest band with a credible midpoint serves you better than one pulled wide at both ends to preserve your options.

- **Know why an offer lands where it lands.** Depth of experience, breadth of scope and demonstrated skill are all defensible. Rewarding whoever pushed hardest is not.

- **Turn the band inwards first.** Compare it with the pay of people already on your payroll. Founders routinely omit this stage, and it is the stage that causes the arguments.

Dwell on that final point. Your own staff will read a published range long before any applicant does. Where an incoming band sits above somebody who has given you three loyal years, a difficult conversation is already on its way. Choose to have it inside a planned pay review, rather than by ambush beside the kettle.

## Writing the Line Itself

One line carries the number. Everything around it still has to read as though a person wrote it. Many employers add a short explanation of how the figure is arrived at, something like: your position within this band reflects what you have done before and how much you will own here. Answering that in advance heads off the awkward version of the question, and it invites a sensible conversation about level instead of a negotiation.

Never park the words "competitive salary" beside a real figure. The phrase contributes nothing and it makes the number look provisional when you meant it to look firm. Where share options, bonuses or a working pattern form part of the package, give each a line of its own with real detail, so nobody has to guess when comparing you against another employer. The same discipline applies to the rest of the wording, as our guide to [writing adverts that do not exclude people](/inclusive-job-adverts-equality-act-uk) sets out.

Brief your own people before the vacancy is published. Hearing it from you is a completely different experience from finding it on an aggregator at the weekend.

## What Happens at the Offer Itself

Publishing a band changes the shape of the offer conversation, usually for the better. The question is no longer what somebody will accept. It becomes where inside the band this particular person sits, and why, which is a question with an answer you prepared weeks ago.

Say the reasoning out loud when you make the offer. Something like: this lands at the upper middle of the range because you have already run a team this size and we need that from the first month. A candidate who hears the reasoning can disagree with it on the facts, which is a far more productive argument than haggling over a number nobody has justified. It also means that if they do push, you will know within a minute whether they have a case.

## Publish the Band Before Anybody Makes You

Here is our position, and it cuts against the sensible-sounding advice that you should wait and see what your member state does. Publish the band now, in every country you hire in, whether or not a law has arrived there yet.

The reason is not compliance. It is that the hard part of this work is internal and the deadline does not help you with it. Building a band forces you to decide what a level is worth, then look at what the people already on that level take home, and that second look is where the uncomfortable discoveries live. A regulator's date does not make that conversation easier. It only guarantees you will have it in a hurry, with a vacancy open.

The patchwork is an argument for one policy, not for several. Poland demands the number in the advert, Malta accepts it before the process ends, Britain demands nothing at all. Chasing each of those separately produces three sets of wording, three review cycles and a founder who can no longer explain their own pay logic. One band per level, published everywhere, satisfies the strictest of the three by construction. The thing that genuinely varies by country is the market rate, and that belongs in the band, not in the policy.

Publishing a band tends to produce an internal re-levelling bill within a quarter, and somebody loyal will turn out to be underpaid relative to the range you just printed. That bill is the price of the exercise, not an argument against it, and it is cheaper to pay deliberately than to have it extracted one resignation at a time. The written version of all this should match what you eventually send, which our guide to [what belongs in an offer letter](/job-offer-letter-uk-what-to-include) covers.

Companies that hire across very different markets sit outside this. Hire across markets where the going rate for the same level differs by a factor rather than a margin, and a single published band either overpays in one place or looks insulting in another. Then you need bands by market, with the reasoning written down, which is more work, and the right work. Below that complexity, waiting for a commencement date is not prudence. It is postponement with a legal alibi.

## The Vocabulary

- **Transposition.** The act of converting an EU directive into a member state's own national law.

- **Pay band.** The internal floor and ceiling attached to a level.

- **Pay range.** That band, in the version candidates actually see.

- **Gender-neutral criteria.** Grounds for paying two people differently, skill and responsibility among them, which have nothing to do with whether either is a woman or a man.

- **Pay gap reporting.** The annual publication of average pay differences between women and men, required of larger employers.

## Five Ways First-Timers Get This Wrong

Start with the enormous range. A band running from forty thousand up to a hundred and ten thousand says only that you would rather not commit, and an inability to narrow it almost always means the role itself is undefined.

Next comes advertising a ceiling you will never pay. People anchor on the upper figure. If no offer of yours ever reaches it, your opening call turns into a scrap over a number you made up, and that gets remembered.

Third, treating the published band as an opening bid. Most candidates value a range for the opposite reason: it tells them where they stand and on what grounds. Prepare for a factual conversation rather than a bazaar.

Fourth, waiting until a regulator obliges you. Anything built in a panic is built badly. An hour of quiet work, a spreadsheet, and the last five offers you made will spare you a frantic month later on. Our piece on [building a hiring process that survives growth](/how-to-build-a-repeatable-hiring-process-that-actually-scales-8t1p) shows where pay bands slot into the wider sequence.

The fifth is assuming one band works everywhere. If you hire across several countries, the implementing law, the commencement date and the market rate all differ, and so may the obligation itself.

## What You Actually Need, Which Is a Spreadsheet

Forget software. Five columns are sufficient: the role, the level, the floor, the ceiling, and a line of reasoning. A sixth column holding the review date turns it into something you can still defend twelve months from now.

On market data, use sources you trust and can describe. Salary surveys, the offers you yourself made over the past year, and a conversation with a recruiter who lives in your particular market all qualify. Say which you relied on. Being able to account for the figure aloud is the whole exercise. Judging when pay in your field is moving quickly is a separate skill, and our guide to [reading market signals early](/how-to-read-hiring-market-signals-before-they-hit-the-headlines-7tnz) covers it.

All of this is uncomfortable for one simple reason: it exposes your decisions to view. That exposure is also the entire advantage. Candidates now compare notes within hours, and the founder who can account for a figure calmly, without flinching, is the one they end up believing.

## FAQ

### Do I have to put a salary in a job advert now?

It depends on where the role is based and whether that country has implemented the EU Pay Transparency Directive. On Remote Work Europe's reading of Article 5, employers must give applicants an initial salary or range built from objective, gender-neutral criteria, preferably in the advert and at the latest before a first interview. Take advice for the specific country you are hiring in.

### Which EU countries have actually implemented the directive?

Writing on 8 June 2026, Littler reported that Slovakia, Malta and Italy had passed comprehensive implementing laws by the 7 June deadline while most other member states had not. The same analysis placed Lithuania, Poland and the Czech Republic as partially transposed, with others still holding draft legislation and no commencement date.

### Does the pay gap reporting requirement apply to my startup?

Not yet if you are small. Employers with 250 or more staff face annual pay gap reporting from 7 June 2027 using 2026 data, with smaller organisations phased in later. The advert requirement is the part that reaches a ten-person company first.

### How wide should a published pay range be?

Narrow enough to mean something. A span of seventy thousand communicates only that you would rather not answer. If you cannot tighten the range, the usual cause is that the level and the scope of the role have not been settled yet.


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Source: https://theartofpeople.io/blog/pay-transparency-job-adverts-founders-primer