Salary ranges in job ads under the EU Pay Transparency Directive
Under Article 5 of Directive (EU) 2023/970, applicants have the right to know the initial pay or pay range for a job, based on objective, gender-neutral criteria, either in the job ad or before the interview [1][2][3]. You may also no longer ask about their pay history [1][2][3]. Here is how to set a range you can defend and write it down.
What Article 5 asks
- Pay information up front. Applicants receive the initial pay level or its range for the position. It can be in the vacancy notice or given before the job interview [2][3].
- Objective, gender-neutral basis. The figure has to come from criteria that do not depend on who applies [2].
- No pay history questions. You may not ask applicants what they earn now or earned in previous jobs [2][3].
Countries had to put this into national law by 7 June 2026 [4]. National versions differ. Poland's draft, for example, allows the information to come later than the EU text sets [5]. Read your own country's rule on timing and form before you change your templates.
Vague phrases such as "competitive salary" or "salary to be discussed" do not give the applicant a figure. Commentators read Article 5 as requiring an actual amount or range [6]. Safer to state numbers.
Five steps to a range you can defend
- Find the category. Which group of workers does this role belong to: the same work or work of equal value? Use the same categories as your pay gap report, so the numbers line up.
- Look at what you already pay. Take the current base pay of people in that category. Note the lowest, the median and the highest.
- Check your pay policy. If you have pay scales or bands, the range is usually the entry part of that band. If you do not, write down the criteria you use now: experience, skills, responsibility, working conditions.
- Set the starting range. A new hire usually starts in the lower part of what current staff earn. Keep the range realistic. A range that is very wide tells the applicant little.
- Record why. Keep one line per vacancy explaining how you set the range. If someone asks later, you have the answer.
Worked example
A company hires a "Customer support, level 2" worker, full-time, 40 hours a week. Current annual base pay in that category:
| Current worker | Years in role | Annual base pay |
|---|---|---|
| A | 1 | EUR 41,000 |
| B | 2 | EUR 42,500 |
| C | 4 | EUR 45,000 |
| D | 6 | EUR 47,500 |
| E | 8 | EUR 50,000 |
The median is EUR 45,000. Workers with one or two years of experience earn EUR 41,000 to EUR 42,500. The company pays more for experience under a written rule that applies to everyone. A defensible starting range for the vacancy is EUR 41,000 to EUR 45,000, depending on experience. That keeps a new hire inside the existing structure, so the job ad does not create a new gap in the category.
What to avoid: starting the range above what some current workers earn without a reason, or offering one candidate the top of the range because they asked harder. Both can open a gap you will see in the next report.
Copyable pay statement for a job ad
Pay Starting salary: EUR [min] to EUR [max] gross per year, for [hours] hours a week. Where you start in this range depends on [relevant experience / specific skills], assessed the same way for every applicant. On top of base pay: [bonus scheme / allowances / none]. We do not ask about your current or previous salary.
If you prefer to give the range before the interview instead of in the ad, use the same text in the invitation email:
Before we meet, here is the pay for this role: EUR [min] to EUR [max] gross per year for [hours] hours a week, based on [criteria]. [Variable pay, if any.] You do not need to tell us your current salary.
Changes in the interview itself
- Remove "current salary" and "salary history" fields from application forms and recruiter scripts.
- Asking what an applicant expects is a different question from what they earned. Check how your national law treats it.
- Brief recruitment agencies too. They act for you, and a pay history question from them is still a pay history question.
- Keep the range in the ad consistent with the range in the offer. If you go above it, write down why.
Why this connects to the rest of the directive
Every hire changes your averages. If you start new hires at different points for men and women without an objective reason, it shows up in the category gap that larger employers must report under Article 9, and a gap of 5% or more that is not justified or fixed within six months leads to a joint pay assessment [1][7]. Workers can also ask for the average pay by sex in their category [1][8]. A clear range at the start is the cheapest place to prevent all of this.
Related guides
- Gender pay gap report template
- How to answer an employee pay information request
- Spreadsheet, tool or consultant: which way to prepare
Sources
- Directive (EU) 2023/970, Articles 5, 7, 9 and 10 (EUR-Lex)
- Forvis Mazars, EU Directive 2023/970: employer obligations and risks (Article 5(1) and 5(2))
- Compound Law, Pay Transparency Directive Germany employer guide (Article 5)
- Clifford Chance, Pay transparency directive (transposition date 7 June 2026)
- Lockton, Poland to implement pre-employment requirements of the EU Pay Transparency Directive
- Innovires, Pay transparency in hiring 2026 (vague salary wording)
- Mondaq, Pay Transparency Directive: what is a joint pay assessment
- GGI, Strengthening gender pay equality: the 2023/970 Directive (Article 7)
This guide explains the rules in plain language. It is not legal advice. Check your own country's law and, when in doubt, ask a qualified adviser.