What recruiters and HR professionals should know about pay transparency through the recruitment lens.
Following on from my guide for HR directors and Leaders in October, link here I thought it was good to share some tips for the recruitment specialism.
So firstly, Ireland will miss the EU’s 7th of June 2026 deadline for transposing the Pay Transparency Directive into national law. Don’t worry, they are the first member state to publicly acknowledge the missed transposition, due to drafting and consultation delays. Always good to be first a something.
But don’t think this will be put on the backburner as the directive has not been delayed, cancelled, or kicked out. The legal requirement still applies, and the enforcement of it is expected to be pragmatic in the early stages.
It is coming, and the shape of it is already visible in countries like Poland, which moved ahead of the deadline.
For Irish agency recruiters and in-house recruitment teams, now is exactly the right time to look to our Polish friends and start adapting.
What Poland Did First
As of the 24th of December 2025, employers in Poland are required to provide candidates with information on remuneration at a specified stage of the recruitment process, this is an initial but significant step towards the full implementation of the EU regulations.
Three obligations stand out as most relevant for recruiters:
1. Salary ranges must be disclosed early and they must be credible.
In recruitment processes conducted without publishing a job advertisement, such as direct search or headhunting then remuneration information must be provided to the candidate before the first meeting. And the range cannot be a broad. The Polish rules are explicit: a range of roughly PLN 5,000–15,000 (€1,150–€3,450) would be considered unreliable, whereas something like PLN 8,000–10,000 (€1,850–€2,300) provides a credible negotiating reference point. Excessively broad ranges are viewed as contrary to the spirit of the regulation.
To put this in an Irish context: Imagine posting a Senior Finance Manager role in Dublin at €45,000–€145,000. Nobody is impressed. A range of €90,000–€110,000 tells a candidate something real. This is not California, where job ads sometimes list ranges up to $999,000, the kind of “transparency” that is, in fact, no transparency at all.
2. Asking about salary history is gone.
Polish provisions now explicitly prohibit obtaining information about remuneration in current or previous employment relationships. The assumption is that remuneration should be determined based on the value of the position and the candidate’s competencies, not their compensation history. Making an offer dependent on a candidate’s prior earnings may be considered a form of unequal treatment.
3. Inconsistency is the real legal risk.
Most employers think the danger is simply not having a salary range to publish and that once they have a number on the job ad, they are largely protected. Reality is different to that view.
Consider what inconsistency looks like in practice. So internally a company has two Senior Project Manager roles, one in IT, one in Operations, broadly equivalent in seniority but historically paid differently. Under a transparency led establishment, those roles sit visibly side by side. If the pay difference cannot be explained by objective, documented criteria, that is a potential equal pay liability, particularly if there is a gender imbalance between the two teams.
Or consider a role advertised at €60,000–€75,000 where one hiring manager always offers at the top of the band and another at the bottom, with neither documenting why. Two employees end up in identical roles on a €12,000 difference. The directive shifts the burden of proof to the employer to demonstrate that difference is objectively justified. Without documentation, then they cannot.
Publishing a salary range is only the starting point. What matters is that every offer within that range is made on consistent, documented, objective grounds and that the process is the same regardless of who the candidate is. “We paid her less because she had less experience” is not a defence if the experience assessment was never documented.
What Ireland Is Likely to Adopt
Early focus in Ireland is likely to be on pre-employment pay transparency, specifically pay ranges provided in advance as well as a ban on pay history questions. More complex “work of equal value” requirements may follow later but should be considered.
Something to note is the draft Equality and Family Leaves Bill which is related to the pay transparency directive. It goes beyond simply requiring a pay range and prohibits the advertising of a role where this information is not included. In other words, the obligation is likely to be stricter than having a range available on request, it will need to be upfront and in the job ad itself.
Irish Hypothetical Examples
Scenario 1 — The headhunt call (agency recruiter): A recruiter at a Dublin search firm is approaching a CFO candidate on LinkedIn on behalf of a professional services client. Under the incoming rules, the recruiter should not be making that first approach without an agreed salary range already locked in with the client. “Competitive package” is not a range. The recruiter needs to be able to say, before that first conversation: “The role carries a base of €150,000–€175,000 plus bonus and benefits.” If the client won’t commit to a range at brief stage, that is now the recruiter’s problem to solve before picking up the phone.
Scenario 2 — The internal job ad (in-house HR): A tech company in Cork is advertising a Senior Product Manager role internally and externally. Under the Directive, the salary band must appear in the posting. Advertising it as “DOE” (depending on experience) will not be compliant. The HR team needs an agreed band, say, €95,000–€115,000 base before the role goes live anywhere.
Scenario 3 — The salary history habit: A hiring manager at a Galway-based MedTech firm is conducting a first-round interview and asks, as they always have, “What are you on at the moment?” That question is going away. The conversation shifts to: “The band for this role is €70,000–€80,000 base. Does that work for you?” Managers who haven’t been trained on this will need to be.
Scenario 4 — The inconsistent offer: Two candidates, one male and one female are put forward for two open marketing specialist roles. Both are at a similar level with comparable experience. One receives an offer at the top of the band, one near the bottom, with no documented rationale. Under the incoming rules, that difference needs to be objectively justifiable and documented. The burden of proof will shift to the employer if a claim arises.
A Note on the “First Meeting” Question for Agency Recruiters
One question that will matter for agencies doing executive search, is whether the disclosure requirement start before the first meeting with the agency, or before the first meeting with the hiring client?
The Polish model points towards it meaning the first substantive interaction with a candidate, wherever it occurs. It would be wise for Irish agencies to treat this as before any qualifying conversation, not before the client introduction. If you are reaching out to someone, you should already have an agreed range from the hiring client before you make that call. This has a real operational implication and agencies will need to nail down the salary range with the client as part of the brief, not as an afterthought.
What Exactly Is a “Salary Band”? Base, Total Comp, or Something Else?
This is where it gets very nuanced, and where a lot of practitioners are confused right now.
In short: the Directive’s definition of pay is broad. It includes base pay, variable pay, bonuses, benefits, allowances, severance, and in-kind compensation. For the purposes of internal reporting and equal pay assessments, employers will need to account for the full picture.
However, in recruitment advertising, most employers are currently expected to disclose the base salary band for the role. This is the most straightforward element to communicate and compare, and it is what most countries implementing the Directive have led with in job ads. There are open practical questions for employers about whether to disclose base salary only or the total target compensation, and whether to provide the full pay range or a partial range typical for newer hires. These questions have not yet been definitively answered in Irish or EU implementing guidance, so watch this space.
Benefits in Kind (BIK): Company cars, health insurance, share schemes, and similar BIK items fall within the Directive’s broad definition of remuneration for reporting and equal pay purposes. Any benefits in addition to the ordinary basic or minimum wage which the worker receives directly or indirectly, whether in cash or in kind, should be considered. This includes travel, housing and food allowances, and occupational pensions. For a job ad, it is good practice to describe significant BIK items clearly (e.g. “company car or car allowance of €8,000, private medical insurance, pension contribution of 6%”) rather than putting them into a brief “excellent benefits package.” In the job ad.
Performance-Related Bonuses: This is where it gets complicated, particularly for roles where a meaningful portion of total pay is variable. Bonuses, commissions, annual incentives, and other variable elements are in scope for the Directive’s broader pay definition. But how do you disclose a bonus in a job ad when the bonus itself depends on factors that are uncertain when initially hiring.
The emerging consensus is:
- If the role has a target bonus (e.g. “up to 20% of base salary”), that should be disclosed alongside the base band. So the ad would read: “Base salary €85,000–€100,000 plus annual bonus of up to 20%.”
- If a portion of the bonus is based on individual performance and another portion on company performance, both elements should be described. For example: “Annual bonus scheme of up to 20% of salary, split 50% on individual targets, 50% on company performance.” This gives the candidate a realistic sense of what is guaranteed versus what is at risk.
- Where a bonus is entirely discretionary with no target or formula, describing it as “discretionary bonus” is still better than silence, but employers should be aware that wholly discretionary bonus structures attract scrutiny under a transparency regime, because “discretionary” can easily disguise inconsistency or discrimination.
A practical example in an Irish context: a Sales Director role in a Dublin-based SaaS company might carry a base of €120,000–€140,000, with an on-target earnings (OTE) figure of €200,000. The right approach is to disclose all of this, base band, OTE, and the structure of how the variable element is earned. Candidates will increasingly expect it, and the law will require it.
Practical Steps You Can Start Embedding Now
For agency recruiters:
- Ensure you have a signed-off salary range, including base and any significant variables and benefits as a non-negotiable part of your client brief before commencing any search. No range, no search.
- Stop asking candidates what they currently earn. Instead, your qualifying conversations should be around expectations and the role’s value.
- Where you advertise roles, include a salary range. “Competitive” is not a number.
- Document your conversations, especially when you disclosed the range, and to whom.
For in-house HR and talent teams:
- Retire or remove from an ATS any box that includes a “current salary” or “last salary” field.
- Build documented, defensible salary bands for every role. The bands need to be realistic, a range so wide it is meaningless will not be compliant.
- Describe your bonus structure clearly in ads and at offer stage, the split between individual and company performance is something candidates are entitled to understand.
- Train your hiring managers, not just HR. A manager asking “what are you on?” in an informal coffee will expose the organisation to risk.
- Invest in market salary data. With salary history off the table, benchmarking against external surveys and competitor pay data becomes your primary tool.
The Bigger Shift: From Salary History to Market Intelligence
Perhaps the most profound change for how recruiters operate day-to-day is the end of salary history as a negotiating anchor. For years, knowing what a candidate earned and drafting an offer around it was standard practice. That approach is ending.
What replaces it is market intelligence. Agencies that invest in robust, current salary benchmarking by function, sector, and level will be far more valuable to clients than those who relied on candidate self-reporting. Internal HR teams will need salary surveys and regular competitor analysis to keep their bands current and credible.
The good news for recruiters who adapt early is that you will be ahead of the curve when the Irish legislation lands, and you will be the trusted advisor your clients need in a more transparent market. If you are seen educating them when other agencies are not will only help build credibility and trust with the client.
The legislation may be delayed. The direction of travel is not.
References & Further Reading
Poland – Source Article
- Accace. Pay Transparency in Poland. Available at: Accace
EU Pay Transparency Directive – Core Legislation & Definition
- European Council. Pay Transparency Directive Overview. Available at: Council of the European Union
- DCI Consult. Understanding the EU Pay Transparency Directive. Available at: DCI Consult Blog
- Outsolve. EU Pay Transparency Directive: What Employers Need to Know. Available at: Outsolve
- Ravio. EU Pay Transparency Directive: Complete Legislation Guide and FAQs. Available at: Ravio
Salary Bands, Bonus & Total Compensation
- HRSoft. EU Pay Transparency Directive 2026 & Global Compensation. Available at: HRSoft
- WorldatWork. EU Pay Transparency Directive: What Sales Comp Leaders Need to Know. Available at: WorldatWork
- BambooHR. EU Pay Transparency Act: What to Know and How to Prepare. Available at: BambooHR
Ireland – Status, Legislation & Employer Guidance
- RTÉ News. Pay Transparency Directive: What It Means for Businesses. Available at: RTÉ News
- The Irish Times. Employers Won’t Be Penalised as Ireland Misses Deadline. Available at: The Irish Times
- The Irish Times. Uncertainty on Delivery of Pay Transparency as Government Fails to Take Clear Position. Available at: The Irish Times
- Littler. Ireland: It’s Time for the Government to Be Transparent About the Pay Transparency Directive. Available at: Littler
- L&E Global. Ireland: Update on EU Pay Transparency Directive 2023/970 and What Employers Can Expect. Available at: L&E Global
- Teamed. Ireland Misses EU Pay Transparency Deadline: What Now. Available at: Teamed
- A&L Goodbody. Implementation of the EU Pay Transparency Directive in Ireland: Where Do Things Stand?. Available at: A&L Goodbody
- Ogletree. EU Pay Transparency Directive Implementation in Ireland. Available at: Ogletree Deakins
- Personio. EU Pay Transparency Directive: HR Guide 2026. Available at: Personio
