Directive guide

Talking about pay: the manager's guide

By Mihai Postolache, founder of Egalis · Updated 26 September 2026

In short

The ground is shifting: once your national law applies, pay-secrecy clauses are unenforceable, workers can request the averages by sex for their category (answered within 2months) and, from 2027, the gap of larger employers becomes comparable. The managers who do well in this era can do one thing the others can’t: explain the criteria behind every pay decision they make.

1. What changed, in one paragraph

Before: pay questions could be waved off, and secrecy clauses made the wave stick. Once your national law applies: any worker can get their category’s averages by sex in writing, colleagues can compare notes lawfully, and — for employers with 150+ employees from June 2027, 100+ from 2031 — the overall gap is published. The information asymmetry that made “we don’t discuss salaries” a strategy is gone — what remains is whether your numbers have explanations.

2. The three answers that always work

To “how is my pay set?” — name the criteria: the category’s range, where the person sits in it and why (seniority, qualification, documented performance). If you cannot name them, that is the real problem to escalate.
To “do others earn more?” — the formal channel: a written request gets the averages by sex for their category within 2months. Never quote individual colleagues’ salaries.
To “this feels unfair” — criteria plus date: what explains the difference, or when it will be corrected. Document the conversation.

Never improvise a denial

“There is no gap here” said casually by a manager, contradicted later by the category averages, reads as concealment in a dispute — and the burden of proof sits with the employer. Route to the channel; don’t freelance.

3. For HR: make the criteria conversation possible

Managers can only point to criteria that exist. That means: job evaluation done and versioned, pay ranges per category, progression criteria accessible to workers (Art. 6), and a one-page brief for managers on the formal request channel. Egalis generates the category ranges and tracks every request’s clock — the manager’s script stops depending on memory.

4. The upside nobody advertises

Teams where pay logic is explainable negotiate less, leak less to competitors’ recruiters, and file fewer claims. Transparency is only a threat where the numbers can’t be explained — everywhere else it is cheap retention.

Frequently asked questions

An employee asks me directly: "do men on our team earn more than me?" What now?

Don't guess and don't deflect. Point them to the formal channel — a written request answered within 2 months with the averages by sex for their category — and flag the request to HR the same day. An improvised answer, right or wrong, becomes evidence.

Can I still tell people not to discuss salaries?

No. Under the Directive, workers cannot be prevented from disclosing their pay for the purpose of enforcing equal pay (Art. 7(5)) — once your national law applies, instructing your team to keep salaries quiet is itself an infringement.

What if the honest answer is "yes, there is a gap"?

Then the conversation is about the criteria and the plan: what objectively explains the difference, and if nothing does, when it will be corrected. A named criterion plus a date beats any evasion — and the law forces exactly that pair anyway.

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