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EU Pay Transparency Directive advisory

The EU Pay Transparency Directive is a governance test.

Explaining every pay outcome through objective, documented and gender-neutral decisions.

About Roth & Del Aguila Consulting

The Partners

Portrait of Rane Roth

Rane Roth

Founding Partner, Job Architecture & Reward

Senior adviser to executives and boards on job architecture and reward, from first design to enterprise-wide rollout.

  • Advised a standing remuneration sub-committee of the executive board at Norges Bank & Norges Bank Investment Management
  • Korn Ferry-trained: builds architectures that serve pay equity, benchmarking
  • Operational HR and HRIS implementation
Portrait of Jorge Del Aguila

Jorge Del Aguila

Founding Partner, Governance & Strategy

Senior executive and board member advising on strategy and corporate governance, with 15+ years across banking and other industries.

  • Executive and board roles across banking, aviation, wine and multi-sector holdings
  • Strategy, corporate governance and M&A, with international board experience

The shift

Transparency changes the conversation

Success will be judged not by the outcomes reported, but by the ability to show they came from objective, documented, gender-neutral decisions.

What is changing

  • Employees gain access to pay information
  • Organisations must explain how decisions are made
  • Regulators gain visibility into pay outcomes
  • Gaps between policy and practice become visible
  • Explaining decisions matters as much as making them
  • Risks include reputational damage, retroactive uncapped compensation claims, exclusion from public procurement

What employees will ask

“How was my pay determined?”

“Why did another employee get a different outcome?”

“What criteria govern progression and reward?”

“How does the organisation ensure fairness?”

What this is not

Visibility, not redesign

The Directive does not require organisations to eliminate all pay differences or fundamentally redesign reward structures.

Differences can appropriately exist because of

Market demand for skills Role complexity and responsibility Performance and contribution Experience and expertise Geographic and labour market factors

Every pay outcome is the end of a chain of decisions

Job architecture
Recruitment
Performance management
Promotion
Compensation

The Directive does not create new decisions. It creates new visibility into existing decisions.

Front-line reality

The manager challenge

Managers will be expected to justify outcomes that employees once accepted without question.

Could managers confidently answer…

  • Why was I hired at this salary?
  • Why is a colleague paid differently?
  • Why did someone else get a larger increase?
  • Why was another employee promoted?
  • Why was my performance assessed differently?

The large-employer reality

Similar grades, different rewards

Roles at comparable levels can carry materially different reward opportunities.

Market premiums for specialists

Technology, cyber, data and quantitative roles often attract significant premiums.

Legacy structures and geography

Acquisitions and reorganisations leave inherited structures, across countries with different labour markets.

Differences are legitimate. Transparency puts the focus on how consistent and explainable they are.

Across the organisation

The alignment challenge

Employees, regulators and other stakeholders will evaluate pay decisions holistically.

One question about pay leads to questions about

Role evaluation
Performance assessment
Career progression
Compensation decisions

Sustainable compliance requires alignment between

HR and Reward
HR Business Partners and business leaders
Legal and Compliance
Employee Relations
Data, reporting and governance
Countries and regulatory environments
Why act now?Decisions made today become the evidence used to explain tomorrow’s outcomes.

Where we help

Why an independent perspective

Many of the hardest issues are organisational rather than technical.

What independent advisors bring

  • An external view, free of historical decisions
  • Experience from similar transformations
  • Objective challenge to assumptions and practices
  • Extra capacity when demand peaks
  • A neutral sparring partner for leaders and local teams

Helping you tell apart

Practices with a clear business rationale
Practices driven by historical precedent
Genuine governance requirements
Processes that evolved differently across functions, entities or locations

An opportunity to strengthen governance and consistency before transparency increases.

How we work with you

Building readiness

Success depends on showing that decisions are fair, consistent and supported by clear governance.

1

Establish confidence in the foundations

  • Review job architecture and role evaluation
  • Test for objective, gender-neutral criteria
  • Audit pay, performance, promotion and reward practices
2

Strengthen organisational alignment

  • Assess alignment across hiring, performance, progression and pay
  • Identify gaps and risks between processes
  • Prioritise remediation by risk and exposure
3

Prepare the organisation

  • Equip managers for more transparent conversations
  • Develop employee communication and engagement
  • Embed governance, oversight and ongoing monitoring

Executive takeaway

The EU Pay Transparency Directive is not primarily a compensation exercise. It is a governance and organisational effectiveness exercise.

Pay outcomes must be explained consistently, through objective, documented and gender-neutral criteria.

The best-prepared organisations will connect job architecture, hiring, performance, progression and reward before scrutiny arrives.

Trusted clients

Organisations we have worked with

Banks, sovereign wealth funds and industrial groups our partners have worked with.

  • Norges Bank
  • Norges Bank Investment Management
  • SpareBank 1
  • Danmarks Nationalbank
  • Nordic Semiconductor
  • FLSmidth
  • atnorth
  • Bentley
  • Storebrand
  • Nexent Bank

Questions

What leaders ask first

Do all pay differences have to disappear?

No. The Directive does not require organisations to eliminate all pay differences or fundamentally redesign reward structures. Differences can be justified by market demand, role complexity, performance, experience and geography. What changes is that you must be able to explain how each outcome was reached.

Where should we start?

With the foundations: job architecture and role evaluation, the use of objective and gender-neutral criteria, and an internal audit of existing pay, performance, promotion and reward practices.

Who needs to be involved?

HR and Reward, HR Business Partners and business leaders, Legal and Compliance, Employee Relations, and the teams that own data, reporting and governance, across every country you operate in.

Why bring in an independent adviser?

An independent adviser offers a neutral view, experience from comparable programmes, objective challenge and extra capacity. That helps separate practices with a clear rationale from those that simply grew over time.

Contact

Get ready ahead of the new regulations.

Speak to us.

Roth & Del Aguila Consulting hello@rothdelaguila.com