Suppose the EU gave a Pay Transparency Directive and (almost) nobody ratified it

The questions companies are asking us, from what counts as "pay" to how expats and Employer of Record workers fit in, reveal just how operationally demanding this Directive is, even before national legislators have finished their work.

For multinational employers, this is the worst of all worlds. Most want a single compliance standard they can apply group-wide, typically the strictest national implementation rolled out everywhere, because managing 27 parallel regimes is neither practical nor cost-efficient. But that "highest common denominator" approach requires knowing what the highest common denominator actually is. Right now, the picture is constantly changing. 

Nonetheless, the absence of national law does not mean the absence of legal exposure. Companies that treat delayed transposition as a reason to pause their preparations are likely making a strategic mistake. If you have not yet stress-tested your pay structures against the Directive, now is the time to start.

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