Wage policy has long been internal and rarely openly discussed. That is changing. From June 2026, a new European directive requires companies to be more transparent about their pay policies.The reason is not new. The gender pay gap persists, including in Belgium. Employees often have no insight into how wages are determined and therefore find it difficult to assess whether their pay is calculated fairly. Transposition into Belgian law is still to follow, but waiting is not a strategy. Companies that take action now have time to adjust quietly.
What specifically will change and what can you do now?
The new ground rules around wage transparency
The bottom line is simple: employers must be able to explain how wages are established. Not as an administrative exercise, but as an assurance that wage differentials are logical and demonstrable.
Specifically, employers must provide insight into:
- How their wage policy works,
- What criteria they use to determine wages,
- which average wages apply within comparable jobs,
- And why wage differentials exist.
When a pay gap is greater than 5% and cannot be logically explained, an employer must intervene: analyse the gap, explain it and correct it where necessary.
Two elements are crucial here. First, individual salaries are not disclosed. Transparency works at the group level: averages per comparable job, corrected by objective criteria such as seniority and responsibilities. Second, employees are given the explicit right to ask how their pay is structured and how it compares to similar roles. Employers must provide this information.
What will change for your organisation?
The impact of pay transparency extends beyond HR alone.
Recruitment
From June 2026, employers must communicate a starting wage or salary range in the job posting or before the first interview. Asking about a candidate's salary is no longer allowed.
What has not yet been determined: whether non-financial benefits such as a company car or holidays should also be included in that communication. That will be determined by the Belgian transposition. What is already clear: your salary range must be substantiated and you must be able to explain it to a candidate who asks questions.
Pay policy and internal structure
Many organisations have pay policies that have grown historically: negotiated per person, adjusted on entry or promotion, without explicit criteria. Wage transparency forces you to formalise those policies. What factors determine a wage? How do jobs relate to each other? When is a difference logical and when not? Those who cannot answer this unequivocally need to map out their pay policy.
Important: the directive only looks at internal data. Whether your wages are in line with the market compared to other companies is outside the scope. The focus is on internal consistency: equal pay for equivalent work within your organisation.
In this respect, transparency does not mean that all wages must be identical. Differences are allowed as long as they are explainable. Someone who enters with more experience, has completed a different evaluation process or carries more responsibilities is allowed to earn more. But you have to be able to demonstrate that objectively. Those who document this well today will stand strong later.
Reporting
Companies with more than 100 employees are required to report on the gender pay gap. The frequency depends on company size. Companies under 100 employees are outside the reporting obligation, but the other obligations apply to all.
When the reported pay gap exceeds 5% and cannot be explained by objective, gender-neutral criteria, a mandatory joint pay review with employee representatives follows.
The burden of proof is on the employer. Individual employees can also ask questions about their pay position outside the reporting cycle. Those who cannot give a clear answer risk retroactive compensation.
Pay communication starts with managers
Pay transparency does not stop with HR. Managers are the ones who have to explain pay decisions to individual employees, sometimes in conversations that involve emotions. Preparing them well for these conversations gives them a strong tool to build trust.
This is especially true among younger generations. Gen Z, for example, wants to understand why a certain wage is awarded, how it compares to peers and to the market. Transparency is a given for them. An employer who communicates this clearly stands out.
Investing in wage communication is therefore as important as the wage policy itself. A strong policy that is poorly explained is as undermining as a weak policy.
Eight steps to prepare
Belgian legislation is still in the pipeline, but that is no reason to wait. If no national legislation is in place by June, the European directive will come directly into force. Those who start now will have time to adjust quietly and will reap the benefits earlier. A transparent pay policy boosts employees' confidence, increases their commitment and strengthens your employer branding. Benefits you don't have to wait for the legislation to be in place.
Step 1: map out your pay structure
Analyse how wages are structured today: what criteria play a role, are they documented, and are there inexplicable differences between similar jobs? Conduct a pay gap analysis not only at the overall organisation level, but also by function. A global analysis that shows no problem does not rule out differences at specific job level.
Step 2: define functions and career paths
Assign employees to job classes based on the job they do and the responsibilities they carry. Also think about what you include in that comparison: only basic salary and bonus, or also non-financial benefits such as a company car or holidays? Belgian legislation should clarify this, but working out a framework internally already saves time.
Step 3: formalise your pay policy
Translate implicit agreements into explicit criteria. What goals do you want to achieve with your pay policy? How do you want to reward growth in competences and skills? Do you opt for individual or collective performance as a basis? A documented wage policy both legally protects you and makes conversations with employees more concrete. Transparency does not mean that all wages are equal, but it does mean that the principles and choices are clear.
Step 4: review your recruitment process
Make sure wage forks are determined and substantiated per job before communicating them in job postings. Train whoever recruits on the new rules: no questions about pay, just a clear story about how pay is determined by position.
Step 5: prepare managers
Invest in training around pay communication. Managers need to be able to explain pay decisions not only technically, but also in individual conversations where emotions are involved.
Step 6: communicate proactively to employees
Employees will know and use their rights. If, as an employer, you take the initiative to explain the pay policy yourself, you avoid questions turning into discussions. Organise information sessions, share an FAQ that helps employees immediately and make sure they know where to go with questions.
Step 7: plan your reporting
Do you fall under the reporting obligation? Map out now what data you need, who manages it and how to keep it up to date structurally. Data quality takes time, don't wait for the deadline here.
Step 8: involve the right people
Pay transparency is not a pure HR project. It requires cooperation between different departments. Each from their own expertise, but with one common goal: a wage policy that is both correct and explainable. An external partner or social secretariat can provide additional support.
Clarity as a competitive advantage
Pay transparency is changing the way organisations should think about pay, and that is not a bad thing. Those who already have their pay policies in place today will have little trouble with the new rules.
It is not a threat to companies that reward fairly and consistently. It is a framework that brings clarity: to employees who better understand where they stand, as well as to employers who turn that confidence into a stronger organisation.
Legislation will follow. Preparation need not wait.
Our tip? Start mapping out your pay structure today. Companies that address this now will soon be stronger. Both as an employer and as an attractive environment for talent.
