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 group

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 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.

  1. Developing a communication strategy

    What to communicate, when and to whom.

  2. Supporting leadership and HR communication

    Developing key messages and response frameworks.

  3. Employee communication materials

    FAQs, information sheets and internal communication content.

  4. Rollout support and stakeholder coordination

    Supporting the roadmap and collaboration during the rollout.

  5. 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.

  1. Opening Introductions, framework, training objectives
  2. Pay transparency basics Legal background, impact on how leaders operate
  3. Pay questions in the interview What I can ask and what I can disclose as a leader
  4. Active listening – practice Assertive communication, situational exercise
  5. 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.

  1. Full content of the half-day program Every module, with deeper practice
  2. Coaching approach A coaching toolkit for conversations about pay
  3. GROW model A questioning techniques toolkit
  4. Handling difficult situations Career coaching situational exercises
  5. 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 package

100–300 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 + information

30–80 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 training

Why 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

What do you believe in?
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.
Coaching / Executive coaching Leadership skills Organizational development Change management AC/DC, selection HR consulting

Professional experience and references

Trainer, consultant and coach at GROW Group since 2025. Previously led the employer branding, talent management and L&D team at Robert Bosch Kft., and worked there as a regional organizational development specialist and HR Business Partner; started out in recruitment and selection at Waberer’s International.

Key references MOL · Alteo · Nissin · Allianz · PERI · Bosch · Waberer’s

Languages Hungarian, English

Senior trainer · HR consultant

Almási Éva

HR consultant, economist, trainer, DISC and Motivational Maps consultant

What inspires you?
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!
HR BP Recruitment and selection Behavioral Event Interviewing (BEI) Negotiation techniques DISC Motivational Maps Resilience Leadership skills

Professional experience and references

Senior trainer and consultant at GROW Group since 2017. Previous roles: HR consultant and trainer at D.A.S. Jogvédelmi Biztosító, recruitment and selection associate at Exact Solutions, and sales trainer and team leader in the insurance sector.

Key references Vodafone · Lufthansa · Knorr-Bremse · Continental · Béres · Yettel · MOHU · JTI · BAT · Praktiker · Richter · Sanofi · Suzuki · Bosch

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

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