Time to prep managers for the imminent pay transparency conversations
When the EU Pay Transparency Directive arrives, employees will not book a meeting with HR. They will walk straight to their manager. And the majority of those managers have never received a single hour of training on how to have these pay conversations.
The assumption we've always made
For years, the lack of pay transparency actually protected managers from difficult conversations.
Employees didn't know enough to ask the hard questions and when they did, the answer was often a shrug and an "HR decides all of that." Many managers were messengers at best, deflectors at worst. They were never required to understand, own, or explain pay decisions. They simply passed them on. That model is about to break down.
Under the EU Pay Transparency Directive, which member states must transpose into national law by June, employees will have a legal right to request information about their individual pay and the average pay levels, broken down by sex, for colleagues doing the same work or work of equal value.
Employers must also make pay progression criteria easily accessible to all workers. Employees will not file a formal request and wait for an HR response. They will ask their manager. They will ask over lunch, in a one-to-one, or in a moment of frustration after a pay review. If their manager cannot answer confidently, with clarity and empathy, the consequences are significant: grievances, tribunal risk, and ultimately, a complete collapse of trust.
The recruiting manager problem
One of the biggest shifts will be felt by managers who recruit.
For decades, the opening question of many salary negotiations has been: "What are you currently earning?" Managers have used this answer to anchor offers, benchmark candidates and manage budgets. It has felt like common sense.
The directive makes this practice unlawful. Employers will be prohibited from asking applicants about their pay history, and candidates must be given the initial pay or pay range for a role before or during the interview.
This means recruiting managers need a completely new script. Instead of working backwards from what someone earns, they will need to articulate what the role is worth, what the range is, and why they’re willing to offer what they ultimately decide within the range. They will need to defend that range confidently to a candidate who may challenge it.
This change is not about removing negotiation. It is about removing the information asymmetry that has always sat underneath it. When both sides know the range, pay decisions have to be justified on merit, on the role, the skills, and the contribution rather than on who was the best negotiator.
Three conversations managers are not prepared for
In practice, pay transparency will generate three types of conversations that managers currently have no framework for handling.
- The comparison conversation: An employee asks: "I've heard that someone doing the same role as me is earning more. Is that true?" Under the directive, employees will have more data to back up these questions and pay secrecy clauses are not allowed. Managers need to be equipped to explain the pay structure, job evaluation methodology, and the objective criteria behind any differences.
- The candidate conversation: A prospective hire pushes back on the advertised pay range, citing their current salary as justification. The manager must explain why the organisation's pay range is competitive and how it was determined.
- The progression conversation: Employees want to know not just what they are paid, but how and when they can earn more. The directive requires progression criteria to be transparent. Managers need to be able to articulate the pay progression pathway clearly, whether that is linked to skills, contribution, or career framework advancement.
What good preparation looks like
Organisations that are already taking this seriously are investing in structured training for managers, not just policy briefings, but genuine capability-building in how to hold what we call "crucial, candid and constructive" pay conversations.
That means preparing managers with factual knowledge: understanding the pay structure, how roles are benchmarked, where individuals sit within their range, and what progression looks like. It also means developing the interpersonal skills to handle these conversations with empathy and building psychological safety, especially when the outcome is not what the employee was hoping for.
The most important principle is this: it is not the answer that makes a pay conversation go well. It is how the answer is delivered, and whether the employee feels heard and treated fairly throughout the process.
The window is closing
With multiple EU member states working towards 2026 implementation deadlines, and UK organisations with European operations already affected, the time to act is now. Pay transparency is not an HR project. It is an organisation-wide capability challenge and cultural change.
The question is not whether your line managers will face these conversations. It is whether they will be ready when they do.
Supplied by REBA Associate Member, 3R Strategy
We help you attract and retain your people through a fair and equitable approach to pay and reward.
