For many Italian HR departments, pay transparency and salary equity have long been stated priorities, often postponed under the assumption that “there is still time.” That assumption is no longer valid.
With a clear regulatory deadline and a rapidly evolving legislative framework, the landscape is shifting. EU Directive 2023/970, published in the Official Journal of the European Union on May 17, 2023, marks a concrete step toward eliminating unjustified pay disparities, particularly those related to gender.
National implementation is required by June 7, 2026. In Italy, the legislative process is already underway: the first draft approved by the Council of Ministers is now under review by the Parliamentary Committees.
The operational pillars are already clear. Understanding them today allows organizations to transform a regulatory constraint into a strategic opportunity for evolution.
Equal Value of Work: A Guiding Principle for Equity
At the core of Directive 2023/970 is a fundamental principle: equal value of work. While roles may differ in tasks and activities, they can require a comparable level of skills, responsibility, effort, and working conditions—and should therefore be compensated equitably.
In practice, the evaluation of job value is often tied to existing structures or internal formal frameworks. These include national collective labor agreements (CCNL), multinational job grading systems, and performance-based approaches such as MBO policies, performance management, and appraisal systems. While valid, these tools can lose effectiveness over time, becoming formal processes detached from real organizational dynamics.
In a context that increasingly demands transparency and objectivity, the Directive provides a valuable reference framework through four cross-functional evaluation criteria:
- Skills: technical knowledge and capabilities required to achieve expected results
- Effort: physical and mental demands associated with the role
- Responsibility: level of decision-making autonomy and management of financial, human, and operational resources
- Working conditions: environmental, organizational, and time-related aspects, including availability requirements
These criteria, while broad, create a concrete space for action. HR functions can use them to rethink compensation structures and organizational culture. This marks the first real opportunity: moving from formal compliance to meaningful cultural transformation.
Tools and Criteria to Evaluate Roles and Skills
HR departments already have tools to support equity, such as job evaluation and job grading systems. The challenge today is to update them, adapt them to the organization’s context, and communicate them transparently, both internally and externally.
An effective model must reflect the company’s specific characteristics and be supported by robust reporting systems, HRIS infrastructure, and clear, engaging communication capabilities.
Translating these principles into sustainable and shared pay structures requires a structured and tailored approach:
- Analyze the current state of pay distribution (As Is), identifying critical gaps and inconsistencies
- Review roles and define their mission, clarifying expectations for each position
- Translate expectations into evaluation criteria aligned with the Directive (skills, responsibility, effort, working conditions), involving employees in the process
- Adapt job grading systems, avoiding overly standardized “one-size-fits-all” models
- Define consistent pay bands and address any imbalances
- Communicate continuously and transparently through both internal and external channels
- Combine external advisory support with internal listening to align company values and purpose with role responsibilities
Beyond Compliance: The Cultural Value of Transparency
Transparency is the thread running through the entire conversation on pay equity. It does not mean disclosing every detail, but providing context and rationale behind decisions. As Simon Sinek emphasized, people need to understand the “why” behind choices.
This is precisely the shift introduced by the Directive: having clear rules is not enough; organizations must be able to explain them. Pay transparency ultimately depends on the organization’s ability to give meaning and coherence to its decisions.
In this context, HR becomes a central function in building trust and fostering dialogue. For pay equity to be authentic, it must be rooted in organizational values. Only then can technical tools evolve into true cultural levers.
Looking Ahead
With a regulatory framework that is now clearly defined and rapidly approaching implementation, the question is no longer whether to comply, but how.
How many organizations will choose to turn a legal obligation into a concrete opportunity to evolve their culture?
This is not just about compliance, it is about vision. The ability to connect rules with values, tools with people, and data with meaning will define the organizations that lead this transition.
