France, Germany, Sweden: three models for applying the European directive on remuneration transparency

In June 2026, the European directive on pay transparency will become a reality for 450 million citizens. This legislation, adopted in 2023, requires all companies with more than 100 employees to publish their pay gaps between women and men, to inform candidates of the pay ranges, and to justify any gap exceeding 5%. But behind a single text, three approaches are emerging: France, Germany and Sweden apply the same directive according to their social, legal and technological traditions.

There European directive on pay transparencyadopted in 2023, must be transposed in each Member State by June 2026.

Objective: reduce the pay gap between women and men, strengthen the right to information, and establish a culture of salary transparency within European companies.

Behind a common text, three logics stand out: France automates, Germany negotiates, Sweden already applies.

France: transparency through data

With his Professional equality indexmandatory for companies with more than 50 employees, France is a step ahead in integrating the requirements of the directive. The data from the Nominative Social Declaration (DSN) will be used to automatically populate the new salary gap, career development and variable remuneration indicators. For its launch, the application threshold will remain at 50 employeesstricter than the European floor of 100.

👉 In 2024, more than 78% of French companies with more than 50 employees already published their equality index.

Dominant technological solutions:

  • Beqom And HR Figures : pay equity audit modules and correction scenarios.
  • Lucca And ADP DataCloud : DSN automation and compliance reporting.
  • Employee portals : anonymized consultation of internal comparisons.

French logic: industrialize compliance through data, without renouncing social granularity.

Germany: negotiated transparency

Germany favors consultation. The future legal framework will extend to 50 employees the obligations already in force for companies with 150 employees or more. Beyond publishing the discrepancies, employers will have to conduct a joint audit with staff representatives when a difference greater than 5% cannot be justified. THE Federal Ministry of Labor estimates that 30% of companies are not yet complying with existing obligations, a challenge to be corrected before 2026.

Preferred technological solutions:

  • Syndio And PayAnalytics : HR-union co-audit platforms, traceability and justification.
  • SAP SuccessFactors And Workday : multi-subsidiary reporting and European consolidation.
  • Salary correction simulators : budgetary modeling over 3 to 5 years.

German logic: framing transparency through statistical precision and institutional dialogue.

Sweden: transparency as a cultural norm

Sweden is the most prepared country. For more than ten years, companies have been carrying out lönekartläggning, mandatory annual salary audit. Thus the European directive only expands this system with the publication of deviations, the justification of the differences and the filing of a corrective action plan.
A national portalnicknamed PayMirrorwill allow employers from 2026 to submit their reports and compare their data to that of the sector.

👉 More than 90% of Swedish companies already carry out an annual salary audit.

Local technological solutions:

  • Beqom Nordic Suite And Analytics Figures : digital extension of lönekartläggning.
  • “Pay Mirror” portal : public consultation and benchmarking platform.
  • Auto Scheduling Tools : prioritization and monitoring of corrective actions.

Swedish logic: make visible what is already fair.

Three models, the same mutation

Europe is aligned on the same requirement: making remuneration a governed data, but the trajectory differs:

  • there France is based on the data and automation,
  • L’Germany on the consultation and methodological rigor,
  • there Suede on the cultural maturity and systemic transparency.

Behind compliance, a strategic shift is taking place: salary transparency is becoming a governance tool as much as an instrument of social justice.

European “Pay Transparency” solutions

Domain Key function Main solutions
Pay equity audit Detection and justification of deviations Beqom, PayAnalytics
HR Compliance & Reporting DSN automation / reporting ADP, Lucca Payroll
Social co-audit HR/union/works council dialogue Syndio
Sector benchmark Anonymized inter-company comparison HR Figures
HR Data Governance Multi-country centralization / deviation alerts Workday, SAP

For 10 years, the European PayTech emerges as a new segment of HR SaaS, combining compliance, data and HR strategy.

Towards a Europe of wage confidence

Behind the legal obligations, a significant cultural change is taking place. Pay transparency becomes a common language between HR, finance and general management in order to better measure governance. Companies that can turn their compensation data into trust metrics will have a competitive advantage. Now the question is no longer just who earns how muchbut how transparency redefines collective performance.