EU Pay Transparency: The Law That Publishes Real Salary Ranges

Somewhere inside a large asset manager's applicant tracking system sits a number that, for most of this industry's history, a candidate was never allowed to see before accepting an offer. A base range, built from a pay band the firm already uses internally, attached to the exact role being advertised. Not a guess. Not an aggregator's estimate. The number the firm actually intends to pay.

For a growing number of roles, that number is no longer hidden. A European law now forces some employers to put it in writing before you ever sit down for an interview, and almost nobody preparing candidates for this industry has caught up to what that means in practice.

7 June 2026

The deadline it set itself

for every EU member state to have it in force

4 of 27

Countries that made it on time

Slovakia, Italy, Lithuania, Malta

0

UK requirement to disclose a range

the directive does not reach the UK at all

The right you now have, and didn't before

Directive (EU) 2023/970 gives job applicants something specific: the right to receive, from the employer they're applying to, the starting pay or its range for the role, stated in the job advert, handed over before the interview, or given some other way before an offer is signed.

Salary negotiation has always run on an information gap: the employer knows what it's willing to pay, the candidate doesn't, and every negotiating tactic on either side exists because of that gap. A firm that has to publish its number before the conversation even starts has given up a real amount of leverage, whether or not it wanted to.

Why this matters more for a graduate than for a senior hire

A senior candidate can often find out roughly what a role pays through their own network, a former colleague, a recruiter who's placed someone similar. A graduate applying cold has almost nothing else to go on beyond the forum posts and aggregator guesses this industry runs on.

This law is the first mechanism that hands that same candidate a number with an employer's own name on it, rather than a stranger's estimate repeated until it sounds like fact.

What you're entitled to before an interview, precisely

Two separate things happen under this law, and it's worth keeping them apart because they get asked about differently in practice.

First, the employer has to give you the starting pay or its range, based on objective, gender-neutral criteria for the role, either in the vacancy notice itself, ahead of the interview, or in some other way before you're hired. Where a collective agreement sets relevant pay terms for the role, that has to be shared too. Second, and separately, the employer is barred from asking about your pay history, current or past, in any form, written or spoken.

That second part is the one candidates underrate. The old move where a recruiter fishes for your current salary to anchor an offer low, or a form field quietly requires it before you can submit an application, is exactly what this rule exists to stop, wherever it applies.

The one country this genuinely does not reach

Here is the single most likely place to get this wrong: the UK is not in this system. The directive binds EU member states, and the UK left the EU in 2020, so a London-based posting carries no obligation under it at all. An asset manager can publish a real range for the same graduate role in Frankfurt and show nothing for it in London, and both would be entirely lawful.

That doesn't mean the UK has no pay-data rules at all, and it's worth being precise about the difference rather than assuming the UK simply has nothing. Large UK employers already have to publish one aggregate figure a year under existing gender pay gap reporting rules: the average gap in hourly pay between men and women across the whole organisation, the gap in bonus pay specifically, and how many people sit in each pay quartile.

That's a real, useful number about a firm's overall pay structure. It is not a range for the graduate analyst role in front of you, and reading the two as the same thing is the mistake to avoid.

A London posting

• No legal requirement to state a pay range in the advert or before interview
• No ban on asking about your current or past salary
• One aggregate gender pay gap figure published once a year, for the whole organisation
• The number you get before an offer depends entirely on what the firm chooses to share

An EU/EEA posting, once the law applies locally

• The starting pay or its range disclosed in the advert, before interview, or otherwise before you sign
• The employer is barred from asking what you earned before
• No annual aggregate requirement attached to this specific right
• The number is tied to the actual role, not the whole organisation

Why the deadline came and went without much changing

The directive gave every EU member state until the 7th of June 2026 to have it written into national law. That date has now passed, and it is worth being blunt about what happened on it: almost nothing, for almost everyone.

Slovakia, Italy, Lithuania and Malta had comprehensive legislation in force around that date. Greece followed a few weeks later, with the employer-facing obligations only starting from the 1st of November 2026. Everyone else was somewhere between a draft bill sitting in a legislature and no bill written at all, months after their own government's own deadline had already gone by.

The countries that matter most to this industry are the ones still behind

This is the part worth sitting with, because it cuts against the instinct to assume a big, well-publicised EU law simply applies everywhere the day it's due. Germany's own draft was still being discussed in cabinet months after the deadline, with the law itself not expected into force until early the following year and the pay-gap reporting obligations pushed out further still. France was still in a consultation phase, with a parliamentary vote not expected for close to another year.

The Netherlands was targeting the start of the following year. Ireland had openly confirmed it would miss the deadline and was seeking a further year's delay. Luxembourg, the domicile for a huge share of the funds this industry runs, hadn't published a draft at all.

Frankfurt, Paris, Amsterdam, Dublin and Luxembourg are exactly where this industry's European hiring concentrates. A candidate assuming the whole EU flipped on one date in June would be wrong about almost every market that matters to their own job search.

How to find a published range for a role

This is the practical part, and it generalises well beyond any one firm. One large global manager's own graduate analyst posting already carries a linked, dated document breaking its salary ranges out by country and function, proof that the mechanism works exactly as intended once a firm operates in a country where the rule applies. The technique behind it is what's worth learning, because it works on any employer, in any country, for as long as this law keeps expanding.

1. Start on the firm's own careers site, not a job board. A listing re-posted on an aggregator has no obligation to carry a disclosure that the original posting does, even when the source page does.
2. Look for a link sitting apart from the main advert text. It's often titled something close to "salary ranges," "pay transparency," or the region and role name together, rather than folded into the job description itself.
3. Confirm the posting is for a country where the rule is in force. A role advertised out of a country still years from transposing the law is very unlikely to carry a disclosure yet, however similar the job title looks to one that does.
4. Read the figure as a range tied to a country and a function, not as one number. The same graduate role at the same firm can differ by a meaningful amount between two neighbouring countries, because each range reflects that country's own pay scale, not a single global figure.
5. Treat anything without a link like this as an estimate, no matter how confidently it's written elsewhere. A forum post, a graduate-guide aggregator or a recruiter's verbal figure is not the same thing as a number the employer has put its own name to.

Same employer, same role, three different outcomes

Put the steps above together and a useful pattern falls out. The same global manager, hiring the same kind of graduate analyst, can show three different things depending on where the requisition sits.

A New York posting shows a range because local law already requires one. An EU posting shows a range if that country has transposed the directive and the role sits there, nothing if it hasn't. A London posting shows whatever the firm feels like sharing, because nothing legally requires it to share anything at all.

That's not a firm being inconsistent. It's one applicant tracking system obeying several different sets of local rules at once, and a candidate who understands the pattern stops being surprised by it.

How to read a band once you've found one

Finding a published range is only half the job. Reading it correctly is the other half, and it's the step most candidates skip.

A range is not an offer, and it isn't one number

A band exists because a firm is willing to pay different amounts for different levels of experience under the same job title. A true first-time graduate, with no prior internship or full-time offer to weigh against, tends to sit toward the lower half of a graduate-level band rather than the top of it.

The top of that same band is usually reserved for someone entering at the same title but with something extra behind them: a relevant internship at the same firm, a year of experience elsewhere, or a second language the desk specifically needs.

Ask where you'd land, not just what the band is

A candidate who reads a published range and stops there has only done half the work. The stronger move is to ask, directly, where a graduate with your specific background would typically land inside it, and what would move you toward the top rather than the bottom. It's a normal, expected question in a process built around a law designed to make exactly that conversation easier to have.

What the number leaves out: bonus and deferred pay

A published range is not the same thing as total compensation, and in an industry where the bonus and any deferred award can end up being a large share of what someone actually takes home, that gap matters more here than in most other fields.

What the directive requires an employer to disclose before an interview is the starting pay or its range. In practice, that means the base salary a firm genuinely expects to offer for the role. A discretionary bonus, and any part of it paid out as deferred fund units rather than cash, sits outside that figure entirely.

The same pattern holds in the clearest US equivalent: California's own version of this rule defines the disclosed number as the salary or hourly range the employer expects to pay, explicitly separate from bonuses, tips or other benefits.

That's not a loophole being exploited. It's simply what the law was built to fix: the information gap around a starting figure, not a guarantee of everything a role might eventually pay once performance, tenure and deferral structures are layered on top of it.

The directive's own definition of pay is broader than what gets disclosed

The directive's own definition of pay is wide. It covers the ordinary basic salary and any other consideration a worker receives, in cash or in kind, including what it calls complementary or variable components, which is the closest the text gets to explicitly naming a bonus. That wide definition is what a firm's own annual pay-gap reporting has to work from further down the line.

What a candidate is entitled to before an interview is narrower: the initial pay or its range. Those are two different obligations inside the same law, aimed at two different moments, and conflating them is an easy way to expect more from a job posting than the rule actually delivers.

The American version got there first

The EU is not the first place to force a number into a job advert. New York City has required a good-faith pay range in job advertisements since the 1st of November 2022, covering any posting for a role that would be performed at least in part in the city, whether that's an internet listing, an internal bulletin board notice or a printed flyer at a career fair.

California followed just over a year later, requiring a good-faith estimate of the salary or hourly range an employer expects to pay, again explicitly excluding bonuses, tips and other benefits from that figure. Colorado had already gone first among US states, requiring a pay range and a description of benefits in every posting years before either of them.

None of that reaches Europe on its own. But it matters for exactly one practical reason: a genuinely global asset manager runs its recruiting through one applicant tracking system across many countries, and the same graduate role often gets posted into several of them at once.

If that manager also recruits into New York, a New York posting for a comparable role can hand you a real, if not directly transferable, sense of scale even while the equivalent EU or UK posting stays silent.

New York City

required since 2022

California

required since 2023

EU, where transposed

required

EU, not yet transposed

not in force

UK

no requirement

New York and California have required this for years. The EU directive is newer and unevenly in force. The UK requires neither.

What this changes about negotiating

None of this makes negotiation obsolete. What it changes is where the conversation starts, and who's holding the information that used to make a low anchor work.

• A published range removes the "what's your current salary" opener entirely where the law applies, because the employer isn't allowed to ask. That single change removes the most common way a low starting salary gets carried forward into every subsequent job.
• The bottom of a published range is not automatically what a strong candidate should expect. A range exists because a firm is willing to pay different amounts for different levels of experience within the same job title; asking where you'd realistically land inside it, rather than accepting the low end by default, is a normal, expected question.
• A range gives you a number to compare against, not a number to simply accept. A candidate weighing two offers, one with a disclosed range and one without, now has a genuinely stronger negotiating position on the disclosed one, because they know the floor the employer is legally committed to.
• It says nothing about the bonus, so ask about that separately. The published figure answers one part of the compensation question. The size and structure of the bonus pool, and how much of it is typically deferred, is a fair, separate question once you're past the initial pay conversation.

What happens next, and why this keeps moving

Nothing about this settles into place on one date, and it's worth building that expectation in now rather than treating any country's status as final. More member states will cross into force through 2027, not all at once, and each will do it on its own domestic timetable rather than the EU's original one.

The directive's own next milestone, separate from the interview right, is the 7th of June 2027, when larger employers in a covered country first have to publish their own gender pay gap data, including the gap inside bonus and other variable pay.

The practical habit that survives all of that movement is simple: check the specific country and the specific posting each time, rather than assuming last year's map still holds. A market that shows nothing today can show a real range within a year, and a market that shows one today isn't going anywhere.

Mistakes worth avoiding

• Assuming the directive applies just because the employer is headquartered in the EU. What matters is where the specific role sits and whether that country has actually transposed the law, not where the firm's head office happens to be.
• Treating a UK gender pay gap figure as if it answered the same question as an EU salary range. One is an annual, organisation-wide average. The other is a range for the specific role you're applying to.
• Reading a published base range as the whole offer. The bonus, and any deferred fund-unit award sitting on top of it, is a separate conversation this figure doesn't touch.
• Trusting a job board's re-post over the firm's own careers page. The obligation sits with the original advertiser, and a re-listed version has no duty to carry the same disclosure.
• Assuming silence means the firm has something to hide. Across most of Europe, silence on a job posting simply means the local transposition deadline hasn't been reached yet, not that anyone is dodging anything.

Check the country first

A law most people preparing for this industry haven't caught up to has quietly created something new: a real, dated, checkable pay figure, attached to a specific role, in the country where the rule already applies. It isn't universal yet, and where it isn't live, nothing has changed. But where it is, a candidate who knows to look for it is standing on better information than almost every guide written about this industry's pay has ever offered.

Check the country before you check the number. That single habit is the whole difference between reading a real figure and repeating someone else's guess.