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6.11.2025

Wage transparency is coming: turn obligation into opportunity

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Under the slogan ‘equal pay for equal work,’ the European Parliament has voted the ‘wage transparency directive. This directive, which must be transposed into Belgian law by mid-2026 at the latest, imposes an obligation on employers to be open about their pay scales and the criteria they use to determine the wages of their staff. By creating more openness about pay, the European Union aims, among other things, to address the gender pay gap.

So what does this mean specifically for you as an employer? In the article below, we take a closer look at the specific obligations imposed on employers, and what steps you can take today to prepare.

 

From hiring transparency to reporting: the new obligations at a glance

Although the directive provides a rather general framework that has yet to be transposed into more concrete legal texts at the Belgian level, it is already established today that the following obligations will be imposed:

Far-reaching access to payroll information

Both employees and job applicants are given the right to payroll information, and how compensation compares to colleagues with equivalent positions.

  • This is how applicants, even before the first job interview, the right to request information about their initial remuneration and about the pay scale of the published position. It will also no longer be permissible for employers to poll for the current salary of the applicant.
  • Furthermore, you will receive staff the right to request information regarding the remuneration policy within your company. This way, your employees can inquire about the average compensation of categories of workers performing equal or equivalent work. In addition, they may also ask which criteria used to determine wages. These criteria should always objective and gender neutral to be.

Reporting requirement

In addition, the Wage Transparency Directive requires you as an employer to provide on a frequent basis report about the internal wage policy and wage composition to a national authority to be determined. The frequency and deadline for the first report will depend on the size of the company and can be summarized as follows:

Number of employees  Deadline 1e report  Frequency 
≥ 250  June 7, 2027  Annual 
150 - 249  June 7, 2027  Every 3 years 
100 - 149  June 7, 2031  Every 3 years 
< 100  Voluntary (may be required by legislature)  Voluntary (may be required by legislature) 

 

If your company less than 100 employees employs, you are not required by the directive to start reporting. Of note, the directive leaves the choice to the member states, allowing the Belgian legislature to still provide an obligation for smaller employers.

A wage differential of 5% or more that not objectively explained can be, must be provided by the employer within six months be rectified.

 

What if I disregard these commitments?

If, as an employer, you fail to comply with any of the obligations and your employee and/or applicant for employment as a result damage suffered, they are entitled to recover for those damages full compensation demand.

Annoying detail in this context is that the burden of proof is reverse: it is up to the employer to show that any wage differentials are not motivated by discrimination.

 

The clock is ticking: how and when should you take action?

Although Belgium still has until June 7, 2026 to transpose the European Wage Transparency Directive into national regulations, it is already clear: these regulations will be a strong impact have on the remuneration policy of each employer.

However, that does not mean you should wait and see. On the contrary: those who prepare today will have an edge tomorrow. A well-founded and transparent wage policy is not only a legal requirement in the making, but also a strategic advantage in the war for talent.

 

Turn this obligation into an opportunity: a strong pay policy is a strategic advantage

The wage transparency directive makes the design of a wage policy not only expedient, but also required by law. Our advice? Make this commitment a opportunity To get your remuneration policy and supply further on point. For us, a strategically interesting pay policy is not just a fair policy, but one that employees motivates To be fully committed to the strategic targets of the enterprise, all in a tax-optimized framework.

 

 

Ready to strengthen your HR policies?

Our Legal-HR team Supports you in setting up a strategically interesting reward policy and the preparation of a tax-friendly and optimized compensation offer. Thus, you not only comply with the new regulations, but strengthen we also your HR policy and thus your competitive position in the labor market.

Specifically, we can support you with such things as:

  • A legal screening of your current pay policy;
  • Identifying risks and bottlenecks under the guideline;
  • Establish or rework objective compensation and reward criteria;
  • Developing a transparent and legally sound compensation policy;
  • Communication advice towards employees and other stakeholders;
  • ...

Interested? Want to know more?

Feel free to contact us through your customer manager or Business Partner.