Key Points
In recent years, salary transparency has moved to the centre of the debate on business management and human resources. Driven by EU regulation and growing social demand for fairness and clarity in pay policies, this trend is reshaping how organisations manage and communicate compensation.
Beyond regulatory compliance, salary transparency is an opportunity to strengthen organisational culture, improve the employee experience, and reduce risks associated with potential pay inequalities.
For companies, the challenge is no longer simply to adapt to regulation: it is to build robust, coherent, and defensible pay models capable of withstanding both regulatory scrutiny and internal review by their own teams.
What is salary transparency?
Salary transparency refers to the set of measures that make it possible to understand and justify how compensation is determined within an organisation. It does not mean publishing each employee’s exact salary; rather, it means ensuring that pay criteria are accessible, objective, and verifiable.
This includes aspects such as:
- Salary-setting criteria and pay bands.
- Promotion and career progression processes.
- Allowances and variable pay components.
- Pay differentials justified by measurable factors.
Its primary objective is to ensure that people performing work of equal value receive equivalent remuneration and that any differences can be explained by verifiable and consistent grounds.
Why is salary transparency gaining prominence?
Pay transparency responds to several converging business and social needs. On one hand, it seeks to reduce the existing gender pay gap — which, according to the INE, stands at 15.74% in Spain. On the other, it aims to reinforce objectivity in pay decisions and bring greater clarity to internal policies.
In addition, younger generations place particular value on transparency regarding the financial terms of the roles they hold or aspire to. According to the 2024 Human Capital Trends Report by Deloitte, organisational fairness and transparency are key drivers of employee engagement.
“We are increasingly seeing organisations understand salary transparency as a talent management tool, not merely a regulatory obligation.”
— Rafael Martínez, Director of RSTalent at RibéSalat
Current regulatory framework and developments in Europe
Salary transparency has ceased to be simply a recommendation in the field of equality and has become a regulatory priority at European level. EU institutions have promoted measures aimed at strengthening equal pay and ensuring greater transparency in organisations’ compensation policies.
This new regulatory framework requires companies to review their recruitment processes, compensation systems, and the information mechanisms made available to employees.
Directive (EU) 2023/970
The European Union adopted Directive (EU) 2023/970 on 10 May 2023 to strengthen equal pay through salary transparency measures. The deadline for transposition by Member States was set for 7 June 2026. Its main developments include:
- Disclosure of salary bands during recruitment processes.
- A ban on requesting a candidate’s salary history.
- Employees’ right to request pay information.
- Periodic reporting on the gender pay gap (action threshold: 5%, compared with the 25% threshold in force in Spain before transposition).
- An obligation to take action where differences above 5% exist without objective justification.
According to ECIJA Law & Technology, the 5% threshold marks a significant change from the current Spanish framework (25% for enhanced justification of the pay register), which will require closer internal oversight and more precise management of pay data.
The situation in Spain
Spain already has mechanisms related to equal pay, including pay registers, pay audits, and equality plans, regulated by Royal Decree 902/2020 and Article 28 of the Workers’ Statute.
However, the European Directive represents a further step towards stricter requirements in pay management. As of June 2026, Spain had not yet formally completed the transposition of the Directive, although according to Iberley, this does not remove the direct applicability of its principles: the current domestic framework remains binding while express legislative adaptation is awaited.
Key obligations for employers
The entry into force of new salary transparency measures will bring significant changes to how organisations manage and communicate their compensation policies. For many companies, this will mean reviewing internal processes, documenting pay policies, and ensuring that pay differentials can be justified by measurable and consistent factors.
“Salary transparency requires pay decisions to be supported by clear, coherent, and easily explainable criteria. It is not simply a legal duty, but a lever for strengthening the organisation’s internal credibility.”
— Rafael Martínez, Director of RSTalent at RibéSalat
Information in recruitment processes
One of the most significant changes will be the need to provide pay information from the earliest stages of recruitment. This will allow candidates to know the salary range associated with a role before joining the process.
In addition, companies will no longer be permitted to request information about candidates’ previous salaries — a practice which, according to the Directive, perpetuates the pay gap: if a profile had previously experienced discrimination, that inequality was then contractually carried over into the new role.
Access to pay information for employees
Employees will be able to request information enabling them to better understand their position within the pay structure. Specifically, they will be able to access:
- Their individual pay level, in order to understand their position within the company’s pay system.
- The criteria used to determine pay, including the factors taken into account when setting pay differences.
- The average pay levels for comparable categories, broken down by gender, making it possible to identify deviations and ensure equal pay for work of equal value.
Gender pay gap reporting: compliance timetable
The rules establish a staggered timetable for gender pay gap reporting:
| Date | Company size | Frequency | Gap threshold |
| 07/06/2027 | 250 or more employees | Annual | >5% without justification |
| 07/06/2027 | 150 to 249 employees | Every 3 years | >5% without justification |
| 07/06/2031 | 100 to 149 employees | Every 3 years | >5% without justification |
Benefits of a transparent pay policy
A clear compensation policy delivers benefits that go beyond regulatory compliance and have a direct impact on organisational culture, employee trust, and the company’s ability to attract and retain talent.
Improved internal trust
Employees gain a better understanding of how pay decisions are made and perceive a stronger sense of fairness and consistency within the organisation. According to the Accenture Life Trends 2025 Report, only 29% of employees feel their leaders take their interests into account — a disconnect that directly affects engagement and talent retention.
Talent attraction and retention
Organisations with clear pay policies tend to deliver a better candidate experience and reduce voluntary attrition. Data from the LHH Executive Search 2025 study show that more than 70% of executives value purpose and work-life balance as much as salary, and that talent retention depends more on corporate culture than on gross pay alone.
To complement salary transparency with comprehensive compensation solutions, RibéSalat flexible compensation programmes make it possible to optimise total compensation without increasing salary costs.
Reduced labour disputes
The existence of consistent pay parameters minimises claims related to discrimination or perceived inequalities, reducing employment litigation and associated legal costs.
Stronger employer brand
Pay transparency is becoming an indicator of organisational maturity and good corporate governance. Companies that address it proactively strengthen their employer branding and improve their positioning in the labour market.
“Companies that address salary transparency ahead of time usually navigate growth, reorganisation, or the recruitment of specialised talent more effectively.”
— Rafael Martínez, Director of RSTalent at RibéSalat
The risks of failing to act in time
Delaying adaptation to this new environment can have consequences that go beyond the legal sphere. The absence of clear pay policies can affect workplace climate, hinder talent attraction, and increase the company’s reputational exposure.
| Risk | Potential impact |
| Regulatory penalties | Economic and reputational costs |
| Employment litigation | Claims, compensation, and legal costs with no predetermined cap (subject to judicial assessment) |
| Loss of talent | Higher turnover and recruitment difficulties |
| Deterioration of workplace climate | Lower engagement and productivity |
| Reputational damage | Impact on employer branding and external trust |
In addition, a poorly defined pay structure makes it harder to justify pay differentials when challenged. The risk of employment litigation is especially significant: unlike dismissal compensation — which is regulated by the Workers’ Statute — compensation resulting from discrimination rulings is determined by the courts based on material and moral damages, which can lead to unpredictable awards.
How to prepare your company for salary transparency
Adapting to the new requirements calls for a comprehensive review of the pay model. This is not simply about meeting new obligations, but about building a coherent, equitable, and business-aligned compensation system.
1. Review the pay structure
It is advisable to carry out a full review of the pay structure to understand how compensation is distributed across the organisation and identify potential internal inconsistencies. This review should cover:
- Base salary as the main component of remuneration.
- Variable pay components linked to performance or targets.
- Employee benefits, including those included in flexible remuneration plans.
- Salary supplements associated with specific functions or job conditions.
2. Define objective criteria
Pay decisions must be based on measurable and comparable elements that allow pay differentials to be justified consistently. The main factors to consider include:
- Job responsibilities, depending on scope and decision-making authority.
- Professional experience, both internal and external.
- Education and qualifications relevant to the role.
- Individual performance, based on objective assessments.
- Role complexity, in both technical and organisational terms.
The Ministry of Labour job evaluation guide provides a recognised methodological framework for this process, particularly useful for companies with an Equality Plan.
3. Update policies and procedures
Salary transparency requires clear documentation and consistent processes that make it possible to justify pay decisions objectively. It is advisable to review and update pay policies regularly to ensure alignment with current regulation and organisational reality.
4. Train managers and HR leaders
Middle managers and HR professionals will play a key role in communicating pay policies and managing employee expectations. It is essential that they understand the pay criteria applied by the organisation and have the tools required to explain them clearly, coherently, and consistently.
5. Conduct regular audits
Regular audits make it possible to detect deviations before they become legal or reputational risks.
“Many organisations identify historical differences during these reviews that had never previously been examined due to the absence of homogeneous job evaluation criteria.”
— Rafael Martínez, Director of RSTalent at RibéSalat
Salary transparency as a competitive advantage
Salary transparency is transforming people management within organisations. What began as an initiative to combat pay inequality has become a core element of business strategy, talent management, and corporate governance.
Companies that adopt a proactive approach will not only be better prepared to meet regulatory requirements, but will also reinforce internal consistency, improve their ability to attract talent, and reduce employment and reputational risks.
In this context, reviewing pay policies is no longer a future option, but a current necessity. At RSTalent, the People & Talent area of RibéSalat, helps organisations design and implement robust, equitable compensation models aligned with their business objectives.
