As the 7 June 2026 deadline for transposing the EU Pay Transparency Directive (EUPTD) into national law approaches, some organisations may consider deferring action until national implementing measures are finalised. The European Commission has, however, dispelled any speculation about possible delays: no extension will be granted, and Member States are expected to meet the deadline. For employers in Luxembourg, the implication is clear - early and proactive preparation is not merely advisable; it is imperative.
The Directive: Raising the Bar on Pay Transparency
The EUPTD represents a seismic shift in how organisations in the Grand Duchy must approach pay equity, transparency, and reporting. Building on the foundations of gender pay gap reporting, the Directive introduces robust new requirements, including:
- Mandatory disclosure of salary ranges in job advertisements and during recruitment.
- Employee rights to pay information, including individual and average pay for equivalent roles.
- Gender-neutral job evaluation and classification systems, requiring objective, auditable criteria for pay decisions.
- Joint pay assessments where unexplained gender pay gaps of 5% or more persist.
- Significant legal and reputational risks for non-compliance, including fines, compensation claims, and public scrutiny.
The EU’s Message: No Excuses, No Extensions
In response to calls for flexibility or delay, the European Commission has reaffirmed its commitment to the Directive’s timeline. The expectation is that all Member States will have transposed the Directive by June 2026, with the first mandatory disclosures due in 2027 for larger employers. The Commission has also signalled that additional guidance and toolkits will be provided, but these are intended to support, not substitute, timely compliance.
For employers, this means the window for preparation is now. Waiting for national legislation or further clarification is a high-risk strategy that could leave organisations scrambling to catch up, or worse, exposed to compliance failures.
What Does Proactive Compliance Look Like?
At Grant Thornton, we believe that the organisations best positioned for success are those who:
- Conduct a comprehensive current-state assessment of job structures, pay policies, and data readiness.
- Develop or refine job architecture and evaluation frameworks using gender-neutral, objective criteria. Leverage existing structures where possible to minimise disruption.
- Update recruitment and pay policies to ensure transparency and compliance from the outset.
- Implement robust systems and data controls to support accurate reporting and rapid response to employee information requests.
- Establish clear governance and escalation protocols for joint pay assessments and ongoing compliance monitoring.
- Invest in communication and training to embed transparency into organisational culture and equip leaders to respond confidently to employee queries.
The Bottom Line
The EU Pay Transparency Directive is not just another compliance exercise. It is an opportunity to build trust, drive cultural change, and position your organisation as a leader in fair pay. With the EU’s stance on delays unequivocal, the time to act is now
How can Grant Thornton Luxembourg help you?
Our experience supporting clients through regulatory change, most recently with gender pay gap and sustainability reporting, has shown that early, structured action delivers the best outcomes. We offer a modular, end-to-end approach to EUPTD compliance, including:
- Gap analysis and readiness assessments
- Job evaluation and pay structure design
- Policy and process updates
- Systems and data integration
- Training, communications, and change management
- Ongoing assurance and audit support
Contact
If you wish to understand how you could best implement the EUPTD, as well as, sustainability practices in your organisation, please contact Dara Kelly, Head of Advisory at Grant Thornton Luxembourg.