Until now, many Italian HR departments have treated pay transparency and salary equity as long-term goals. Today, with deadlines set and the regulatory framework in place, these priorities can no longer be postponed. EU Directive 2023/970, published in the Official Journal of the European Union on 17 May 2023, sets a clear path toward eliminating unjustified pay differences, especially gender-based ones.
The national implementation deadline is 7 June 2026, but the key requirements are already defined. Companies that start preparing now will not only stay compliant but also gain a competitive edge.
What the Directive Requires
- Pay distribution reporting by 2027
- Employee access, on request, to information on their pay compared to roles of equal value
- Corrective action plans if gender pay gaps exceed 5%
- Retroactive compensation for unjustified disparities
- Sanctions for companies that fail to comply
This is more than a regulatory exercise. Tackling pay disparities early strengthens culture, reputation, and retention, while making employer branding and internal communication more credible.
Equal Value of Work: A Practical Framework
At the core of the Directive is the principle of equal value of work. Different roles may involve different tasks, yet still require a comparable level of skills, effort, responsibility, and working conditions. These roles deserve fair and consistent pay.
To support this, the Directive identifies four evaluation criteria:
- Skills: knowledge and capabilities required for results
- Effort: physical and mental demands of the role
- Responsibility: decision-making authority and management of resources
- Working conditions: environment, organization, schedules, and availability requirements
These criteria give HR leaders a practical framework. The challenge is to move beyond formal tools toward real cultural change.
How HR Can Act Now
Most HR teams already use tools like Job Evaluation or Job Grading. The task ahead is to update them, apply them consistently, and communicate transparently.
A practical roadmap includes:
- Defining expectations for each role and linking them to the Directive’s criteria
- Involving employees in clarifying responsibilities and outcomes
- Adapting grading systems to the company context, avoiding rigid templates
- Reviewing pay bands and correcting imbalances
- Communicating clearly and consistently, both inside and outside the organization
- Balancing external consulting with internal feedback to align pay with values and purpose
Beyond Compliance: Building Trust
Transparency is the real driver of change. It is not about publishing every detail, but about explaining decisions with clarity and context. When employees understand the reasoning, fairness becomes visible.
Here, HR has a pivotal role: building trust, driving dialogue, and connecting pay policies with company values. Technical tools matter, but only values make them credible.
The Road Ahead
The question is no longer whether to comply, but how. Companies that act early will turn a legal obligation into a cultural and strategic opportunity.
This is not just about compliance. It is about vision—the ability to connect rules and values, processes and people, numbers and meaning.
