Pay transparency · EU 2023/970
Not just legal compliance. A shift in mindset.
Pay transparency is not just another HR project; it is a matter of trust, reputation and business. We help you prepare: from knowledge through systems to preparing your leaders.
- June 7, 2026
- deadline for member states to transpose the directive
- 2027
- first mandatory report for employers with 150+ employees, based on 2026 data
- 5%
- an unjustified gender pay gap above this level triggers a joint pay assessment
The directive
What is the Pay Transparency Directive?
The European Union adopted the Pay Transparency Directive (EU 2023/970) in 2023. Its aim is to strengthen the principle of “equal pay for equal work”, in particular by reducing the gender pay gap. Member states had to transpose it into national law by June 7, 2026.
Closing the pay gap
Eliminating the pay gap between women and men (the gender pay gap). In Hungary, this is a particularly pressing issue.
Transparency
Employees can see their own pay and the average pay for jobs of equal value, broken down by gender.
Employer obligations
Pay bands must be shown in job ads. The pay structure is based on objective, gender-neutral criteria.
Enforcement
In pay discrimination cases, the burden of proof is reversed: the employer must prove that no violation occurred.
The question is not whether pay is equal, but whether the differences can be justified.
Who does it apply to?
It affects every employer. Size only determines the reporting.
Select your organization’s headcount, and we’ll show you which obligations to plan for.
How many people do you employ?
Organization with fewer than 100 employees
Regardless of size
- Disclosing pay bands in job ads
- Obligation to inform
- Prohibition of discrimination
Gender pay gap report
No regular report
You have no regular gender pay gap reporting obligation, but the basic obligations apply to you as well.
Organization with 100–149 employees
Regardless of size
- Disclosing pay bands in job ads
- Obligation to inform
- Prohibition of discrimination
Gender pay gap report
Every 3 years
The first report is expected to be due in 2031.
If the gender pay gap exceeds 5% and cannot be justified by objective criteria, a joint pay assessment and corrective measures follow.
Organization with 150–249 employees
Most critical target groupRegardless of size
- Disclosing pay bands in job ads
- Obligation to inform
- Prohibition of discrimination
Gender pay gap report
Every 3 years
The first report is due in 2027, covering 2026 data.
If the gender pay gap exceeds 5% and cannot be justified by objective criteria, a joint pay assessment and corrective measures follow.
Organization with more than 250 employees
Regardless of size
- Disclosing pay bands in job ads
- Obligation to inform
- Prohibition of discrimination
Gender pay gap report
Annually
The first report is due in 2027, covering 2026 data.
If the gender pay gap exceeds 5% and cannot be justified by objective criteria, a joint pay assessment and corrective measures follow.
Why now?
Why does it pay to act proactively?
Preparation takes months, not days. The first report will be based on 2026 data: if your structure is not in order now, it will show.
If you don’t act in time
- The first mandatory report (2027) already shows problematic data
- In pay discrimination cases, the burden of proof lies with the employer
- Compensation with no upper limit
- Exclusion from public procurement and state aid
- Reputational risk based on public data
Those who act early
- A stronger employer brand: transparency attracts talent
- More predictable payroll planning with structured pay bands
- Lower turnover, as trust and engagement grow
- Minimal legal and reputational risk
- A competitive edge in recruiting: the pay band is right there in the job ad
In our experience, these are the biggest challenges within an organization:
- Pay has been a private matter until now; transparency is a significant shift in mindset.
- Pay decisions are often not made according to a consistent logic.
- Pay bands and job structures are often not formalized enough.
- Leaders often lack consistent communication guidelines.
How do we support you?
On three fronts, from knowledge through systems to preparing your leaders
01Knowledge
Information
What is pay transparency, and what do you need to prepare for?
We give a comprehensive overview of the EU directive and the expected Hungarian regulation: what the law requires, what the obligations and deadlines are, and what the typical pitfalls and misconceptions are.
The directive in brief →02System
Consulting on HR processes
We put the background and processes in order
We put the related HR processes in order: pay bands, job architecture, documentation of pay decisions, employee information. Everything that needs to be transparent.
HR consulting →03Change
Change management and leadership preparation
Communication is the key to change
We support the rollout with communication and change management tools, to build business and employee trust. For leaders, we offer half-day and one-day training.
Change management →Consulting
Consulting on the related HR processes
Job architecture
An objective, gender-neutral job evaluation system that organizes positions by scope of responsibility, competencies and working conditions.
Designing pay bands
A compensation structure built on market benchmarks and internal equity, providing a framework for both recruitment and internal career progression.
Documenting pay decisions
Recording the criteria behind setting and raising pay: a transparent, defensible decision logic, even in legal disputes.
Employee information
An internal process that gives colleagues lawful access to their pay information and to average data for comparable jobs.
Change management
We facilitate the change
We support companies in introducing pay transparency with a communication and change management toolkit, so that compliance is seen in the organization not merely as a legal obligation, but as a change that strengthens business and employee trust.
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Developing a communication strategy
What to communicate, when and to whom.
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Supporting leadership and HR communication
Developing key messages and response frameworks.
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Employee communication materials
FAQs, information sheets and internal communication content.
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Rollout support and stakeholder coordination
Supporting the roadmap and collaboration during the rollout.
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Managing change risks
Handling expected reactions and sensitive points.
Leadership training
Two intensities, one goal
Confident, consistent leadership communication in the new system. The system only works if leaders can also communicate about it well.
Half-day training
9:00 – 12:303.5 hours
The fundamentals of the directive and practice in assertive communication, for leaders who need to become confident on pay issues quickly.
- Opening Introductions, framework, training objectives
- Pay transparency basics Legal background, impact on how leaders operate
- Pay questions in the interview What I can ask and what I can disclose as a leader
- Active listening – practice Assertive communication, situational exercise
- Feedback – practice SAID model, with a focus on appraisal conversations
One-day training
9:00 – 16:457.5 hours
The full content of the half-day program, complemented by a coaching approach and deeper practice of difficult situations.
- Full content of the half-day program Every module, with deeper practice
- Coaching approach A coaching toolkit for conversations about pay
- GROW model A questioning techniques toolkit
- Handling difficult situations Career coaching situational exercises
- Unexpected and planned situations Complex cases, group debrief
Who do we help?
Sound familiar?
80–200 employees
Growing SME
- Pay has been set through individual negotiation, without a consistent system
- No internal capacity for legal compliance
- Pay bands will soon have to be disclosed in job ads
We help you prepare for pay band disclosure and build a defensible pay structure.
Full HR process package100–300 employees
Hungarian subsidiary of an international company
- The parent company expects compliance, but local implementation is missing
- The first mandatory report is due in 2027, using 2026 data
- Pay data broken down by gender doesn’t look good
An orderly, defensible pay strategy for the future, backed by pay documentation.
HR processes + information30–80 employees · IT, consulting, law
Professional services firm
- Strong individual bargaining positions make a consistent structure hard to build
- Senior colleagues notice the disparities and leave
- A competitive disadvantage in recruiting without a pay band
A system that strengthens recruiting and retains your best people.
Pay bands + leadership trainingWhy GROW?
Let’s prepare together!
Not just compliance
We bring a shift in mindset and real expertise.
Organizational experience
We know the realities of Hungarian SMEs and large companies.
With you all the way
From information through processes to communication.
Leadership focus
The system only works if leaders can communicate about it, too.
Our experts
The people you’ll work with
Trainer · Consultant · Coach
Tóth Alexandra
Economist, trainer, coach, facilitator
I believe that we can best fulfill ourselves and realize our potential when, day to day, we do what is truly authentic to us, what energizes us and fills us with passion.
Senior trainer · HR consultant
Almási Éva
HR consultant, economist, trainer, DISC and Motivational Maps consultant
It feels good to deliver a training on a topic that connects with participants’ interests and genuinely helps them in their work afterwards. It feels good to give!
Let’s talk!
Let’s look together at where your organization stands now and what the next step should be: an information session, putting your HR processes in order, or preparing your leaders.
Request a callback, and we’ll get back to you within 48 hours.
GROW Group
- office@grow-group.com
- +36 30 999 3308
- 1037 Budapest, Montevideo u. 3/A