Pay Transparency in Practice: Turning Regulation into Fair, Data-Driven Action

10/28/20255 min read

Andras Rusznyak

artificial intelligence expert

Ha magyarul szeretnéd olvasni a cikket, kattints ide

Across Europe — and soon across Hungary — pay transparency is transforming HR from policy-driven to data-driven.
The EU Pay Transparency Directive (2023/970) turns the principle of equal pay for equal work into a measurable, auditable obligation.

By June 2026, every EU member state must adopt local laws that:

  • Require salary ranges in job ads

  • Give employees the right to access average pay data by gender

  • Mandate pay gap reporting for employers with 100+ staff

  • Trigger joint pay assessments if gaps exceed 5%

This means HR can no longer rely on “good intentions.”
The new baseline is quantified fairness — powered by clean data, consistent job architecture, and transparent analytics.

IMPORTANT NOTE:

We utilized generative AI in the making of this article.

Core legislation: Directive (EU) 2023/970 – “Strengthening the application of the principle of equal pay for equal work or work of equal value.”

Timeline and impact:

  • June 2026: Directive transposed into Hungarian law

  • 2027 onward: Employers with 100+ employees must report gender pay gaps every 3 years (those with 250+ employees → annually)

  • Applies to all employment forms, both private and public

Key obligations:

  1. Salary range disclosure: Include pay range or expected level in job postings.

  2. Pay transparency for employees: Workers can request average pay data for comparable roles, by gender.

  3. Pay reporting: 100+ employers must report gender pay gap data to authorities.

  4. Joint pay assessment: Required if >5% gap remains unexplained.

  5. Right to compensation: Employees can claim pay adjustments or damages.

In Hungary:
The directive will likely be integrated into the Munka Törvénykönyve (Labour Code) with the Ministry for National Economy (NGM) and the Equal Treatment Authority overseeing enforcement.
Hungarian companies should expect a local reporting framework linked to existing HR and payroll systems, similar to gender equality declarations already used in EU-funded projects.

The Regulatory Background

From Legal Obligation to HR Analytics Opportunity

Most HR leaders see pay transparency as a compliance risk — but with the right analytics mindset, it becomes a strategic lever for trust, retention, and talent brand.

Here’s how analytics enables a structured, measurable approach.

1. Build Your Pay Data Foundation

You can’t manage what you can’t measure.
Start by auditing and cleaning all compensation-related data sources: HRIS, payroll, and bonus systems.

Actions:

  • Align job titles and families — eliminate duplicates and legacy naming (e.g. “HR Generalist” vs “People Partner”).

  • Add consistent leveling codes (L1–L7) so pay comparisons are fair.

  • Validate FTE status, tenure, and location data — common data gaps distort analysis.

  • Calculate compa-ratios (employee salary ÷ midpoint of band) to detect outliers.

Data required: Job title, level, base pay, bonus, FTE%, location, gender, tenure.
Tools: Excel, Power BI, or Python (pandas).
Skills: Data cleaning, pivot tables, basic descriptive statistics.

📊 Visualization idea: A heatmap showing compa-ratio distribution by department or gender to identify inequity clusters.

2. Define Fair and Defensible Pay Bands

Publishing ranges isn’t just policy — it’s a data validation exercise.

Actions:

  • Define salary bands per role level using statistical spread (e.g. median ± 20%).

  • Compare to market benchmarks (salary surveys, Korn Ferry, Hays, PwC).

  • Run simulations: how many employees sit outside the range, and what correction cost would bring them within tolerance?

  • Prepare candidate-facing ranges (e.g. 85–115% of midpoint) and align messaging with recruiters.

Analytical insight:
Identify whether variability within a level is performance-driven or structural — if two employees with similar tenure differ by >20%, HR must justify why.

📊 Visualization idea: Box plot of pay distribution per level, highlighting median, outliers, and gender splits.

3. Measure Pay Gaps — and Explain Them with Data

Compliance requires more than publishing numbers; it demands understanding why the gaps exist.

Actions:

  • Compute mean and median pay gaps (overall and per comparable group).

  • Use regression models to control for legitimate factors: level, experience, education, region.

  • Quantify the “unexplained” gap — typically anything beyond 5% not justified by data.

  • Document explanations clearly (e.g. “Gap driven by tenure skew in new hires”).

Data required: Base pay, job level, tenure, gender, performance rating, education, region.
Tools: Excel Analysis ToolPak, R, or Python (statsmodels).
Skills: Regression interpretation, significance testing.

📊 Visualization idea: Bar chart comparing explained vs. unexplained gender pay gaps by department.

4. Combine Legal Compliance with Analytics Governance

A strong data foundation must link to governance: who owns what and how it’s reviewed.

Actions:

  • Assign data owners (HR, Comp & Ben, Legal).

  • Set data quality thresholds (e.g. <2% null values in salary fields).

  • Define a review cycle: quarterly data validation, annual pay gap audit.

  • Involve works councils early to align on method and findings.

  • Document models and assumptions — so if audited, your analytics are defensible.

Best practice:
Use data contracts for HR/payroll systems — ensuring schema consistency and audit logs.

5. Communicate with Clarity and Context

Data transparency fails if managers and employees can’t interpret it.

Actions:

  • Create simple visuals for internal communication (e.g. how pay bands are built, where fairness checks happen).

  • Educate managers on interpreting pay bands and addressing questions.

  • Publish summary metrics — not all data — to avoid overload.

  • Track changes in employee trust and engagement after rollout using pulse surveys

Why It Matters Now

Pitfall
  • Publishing without internal validation

  • Wide or arbitrary pay bands

  • Ignoring variable pay

  • Focusing only on gender

  • Treating compliance as one-time

Common Pitfalls and How to Avoid Them

Why it's a risk

Leads to data errors and credibility loss

Undermines fairness perception

Hides inequities

Misses broader inclusion insights

Gaps reappear over time

Data driven fix

Run consistency checks on HRIS/payroll fields first

Base bands on statistical midpoints ± deviation

Include total compensation

Track equity by age, tenure, and location

Institutionalize annual analytics reviews

The Pay Transparency Analytics Checklist

#

1

2

3

4

5

6

7

8

9

10

Task

Map roles to job families and levels

Clean base + variable pay data

Calculate gender pay gaps

Model explained vs unexplained variance

Define and approve pay bands

Communicate pay structures

Engage works council

Publish ranges for roles

Conduct joint pay assessment if >5% gap

Set annual analytics review cadence

Responsible

HR / Comp & Ben

HRIS / Payroll

HR Analytics

HR Analytics / Legal

Comp & Ben

HR / L&D

HR / Legal

TA / HR

HR / Works Council

HR Leadership

Tools

HRIS

Excel / BI

Power BI / Python / R

Excel / Python / R

Market data

PowerPoint / BI

Reports

Website

Shared analysis

Dashboard

Final Thoughts

The EU Pay Transparency Directive is a data governance challenge disguised as an HR policy.
Organizations that treat it analytically — with clear definitions, clean data, and regular measurement — will gain not just compliance, but a reputation for fairness and integrity.

The future of compensation isn’t just about “how much we pay,” but how we explain it — with data, not intuition.

Up next: Thank you for reading this article. We will be posting short snippets on HR Analytics while we are working on season 2 of the larger series. Stay tuned.

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