Pay Equity Made Simple?

Interim Managers Provide Ideal Support for Implementing the EU Pay Transparency Directive

By June 7 2026, the EU Pay Transparency Directive (EU 2023/970) must be transposed into national law—a milestone for greater pay equity and transparency. However, these new regulations also bring complex compliance requirements for organisations, particularly regarding resources, expertise, and time management. Interim managers offer an ideal solution: With their experience and flexibility, they can be deployed on short notice to help organisations implement the directive efficiently and in full compliance with legal requirements.

What is the EU Pay Transparency Directive? 

Employees will soon have the right to request information on how their salary compares to the average salary of colleagues of the opposite gender, as well as those performing the same or equivalent work. This information must be provided within two months. Organisations with 100 or more employees will be required to regularly report on pay disparities, based on company size, and take action if unexplained gaps—such as pay differences exceeding five percent—are identified.

The reporting obligations will apply starting in 2027: 

• Annually for organisations with at least 250 employees.

• Every three years for organisations with 150 to 249 employees. 

From 2031 onwards:

• Every three years for organisations with 100 to 149 employees. 

Small businesses with fewer than 100 employees are exempt from certain obligations under the directive, such as reporting requirements, to minimize administrative burdens. However, they may choose to report voluntarily.

Even during the application process, employers will be required to transparently communicate entry-level salaries or salary ranges, either in job postings or upon request during interviews. Additionally, the burden of proof in cases of alleged discrimination will shift more heavily onto employers. 

The directive aims to establish fair and gender-neutral pay systems. Employers must ensure non-discriminatory processes and future-proof their pay structures. The new regulations provide employees greater transparency and bargaining power, without restricting salary flexibility.

Why Interim Managers are essential for implementing the EU Pay Transparency Directive

Mounir Feldmann, Managing Consultant in Interim Management at Robert Walters, highlights: "An external consultant can not only identify inefficient processes but also implement innovative solutions without bias." 

Interim managers bring not only technical expertise and legal knowledge but also the ability to critically evaluate existing processes. Another key advantage is their independence. Unlike internal employees, they are not influenced by political or social dynamics within the organisation. This objective perspective is invaluable, especially when addressing sensitive topics like pay equity. Interim managers support organisations in establishing fair salary structures while ensuring efficient compliance with legal requirements.

Key skills and profiles of an Interim Manager 

"The required profile of an interim manager depends on where support is needed—whether in IT, legal, or HR," explains Mounir Feldmann.

Interim managers with experience in the following areas are particularly in demand: 

Change Management

The Interim Transformation Manager supports organisational transformation by analysing existing HR, salary, and reporting processes and developing a comprehensive change management plan. This plan includes stakeholder mapping, risk analysis, and communication strategies to foster acceptance of the changes both internally and externally. Additionally, they conduct workshops and training sessions for leaders and employees to enhance understanding of the new requirements. Progress is continuously monitored and evaluated using KPIs. 

HR Processes

The Interim HR Business Partner ensures the alignment of HR processes and acts as a bridge between departments and HR. They assist in creating or adjusting job architectures and role evaluations, collaborate with leadership on new salary structures, and coordinate internal projects to meet the directive's requirements. Furthermore, they ensure consistent use of HR tools such as SAP HCM or SuccessFactors and develop guides or FAQ documents to inform employees about the directive. 

Compensation & Benefits

The Interim Compensation & Benefits Manager analyses current salary data by gender, position, and location to identify potential inequalities. They design new or updated pay systems and salary bands in line with transparency obligations. In addition, they prepare legally compliant documentation for audits and regulatory reports, implement reporting structures to evaluate the gender pay gap, and advise senior management on strategic salary decisions. 

Data Analysis

The Interim HR Data Analyst establishes a reliable data foundation to meet the reporting obligations of the Pay Transparency Directive. They consolidate and clean employee data from various sources, develop standardized data models for salary and employment information, and create dashboards and reports on key metrics such as the gender pay gap or salary bands. In collaboration with the IT department, they ensure data integrity and prepare automated reporting processes. 

Compliance and Labour Law

The Interim Legal Counsel or Compliance Manager reviews company policies for compliance with the EU directive and national labour laws, making adjustments where necessary. They develop internal compliance guidelines, advise the HR department and senior management on employment law matters, and train leaders on equal treatment and reporting obligations. Additionally, they support internal audits and maintain communication with regulatory authorities. 

IT Systems

The Interim IT Project Manager or Application Specialist evaluates existing IT systems for required adjustments related to pay reporting functionalities. They implement or enhance modules in systems such as SAP, Microsoft D365, or LucaNet, work closely with HR Data Analysts and Compensation Managers to ensure seamless data integration, and develop interfaces to automate reporting processes. Finally, they evaluate new functionalities, train relevant employees, and document all changes. 

Beyond these specific areas, interim managers often function as a bridge between departments—such as HR, IT, and Compliance—to ensure smooth collaboration. They frequently take responsibility for communication with external stakeholders like regulatory authorities or labour unions.

Challenges in implementation 

While many organisations recognize the importance of the EU Pay Transparency Directive, long-term planning is often lacking. Based on his experience, Mounir Feldmann explains: “The various tasks require a structured approach, starting with requirements engineering to clearly define needs, followed by data analysis and cleansing to establish a solid foundation, and finally the technical implementation within IT systems. Regular reporting is essential to ensure that measures are sustainable and meet the directive’s requirements.”

Another significant challenge is data quality. Only consistent and transparent data can enable organisations to comply with the directive. Tools like Power BI or other analytics platforms play a crucial role here. Interim managers are particularly skilled at responding quickly to unforeseen challenges—whether due to a lack of internal resources or insufficient data quality. With their experience across industries and projects, they can rapidly develop and implement effective solutions. 

Project duration and costs

The typical duration of a project to implement the Pay Transparency Directive ranges from six to twelve months. Feldmann recommends a minimum project length of four months to analyse initial results and make necessary adjustments. 

For cost planning, the following average daily rates for interim experts from our current Interim Management Report 2026 serve as benchmarks:

• Head of Payroll: €1,100
• HR Business Partner: €1,200
• HR Advisor: €1,300 
• Data Analyst: €1,000
• Data Scientist: €1,100 
• Data Protection Officer: €1,200

Mastering Change Processes with Interim Management

With their diverse expertise, interim managers are ideally positioned to address the challenges posed by the EU Pay Transparency Directive. Whether in change management, compliance, or IT adjustments, selecting the right profile is critical to the success of the implementation process. 

Organisations should plan early and rely on experienced professionals—not only to ensure legal compliance but also to remain competitive in the long term. Transparency and consistency are essential for meeting the new legal requirements effectively.

"An interim manager brings an objective external perspective to the organisation, which is crucial for implementing regulatory directives. From a compliance standpoint alone, involving an external consultant in developing solutions is highly advisable. They also bring extensive industry and project experience, introducing methodologies, benchmarks, and agile approaches into rigid processes. Their unbiased viewpoint helps identify inefficiencies and implement innovative solutions without hesitation," summarizes Mounir Feldmann. 

Discover the benefits of Interim Managers in detail.

Do you need support finding the right interim manager? 

At Robert Walters, we provide tailored solutions in interim management, customized to your specific needs and backed by industry-specific expertise. Contact us today to benefit from our experience in interim management.

Approach the implementation of the EU Pay Transparency Directive with confidence—submit your interim mandate directly here. 

Additionally, explore our Interim Management Report for up-to-date insights into salary and labour market trends within interim management.