The principles of the European Pay Transparency Directive are by now widely known: creating greater transparency about remuneration levels within companies and introducing various measures and reporting obligations to reduce the gender pay gap.
The directive should have been transposed into national law by 7 June 2026. As you probably know, neither Belgium nor many other Member States met this deadline.
As a result, there is currently no Belgian transposition legislation in place for the private sector.
The social partners and the National Labour Council were negotiating amendments to existing collective labour agreements in order to embed the European requirements within the legal framework, but they encountered several legal and practical issues in the process.
The federal government therefore requested a six-month extension in early June.
Although the new rules are not yet in force in the private sector, the direction remains clear: employers will need to provide a stronger basis for their pay structures using objective and gender-neutral criteria. Many companies are using the current transition period to review their job classification systems, pay policies and internal processes.
The Centre for Excellence in Strategic Rewards at Vlerick Business School – of which Vanbreda is a proud partner – surveyed 36 members in late 2025 under the guidance of Prof. Xavier Baeten in order to assess the state of pay transparency. The three key conclusions from this survey are:
The results show that most organisations have moved beyond the awareness phase and are taking steps towards implementation. Many have already analysed the gender pay gap and initiated projects regarding job evaluation, pay structures and job architecture. At the same time, tangible progress is still relatively modest: only 17% report significant progress compared to the previous year, while 39% report limited progress and 8% no progress at all.
Three major challenges are emerging regarding implementation. First, the absence of definitive national legislation is causing hesitation in decision-making. Second, organisations are facing difficulties regarding data and methodology – for instance in defining comparable roles, valuing fringe benefits and calculating adjusted pay gaps. Third, direct managers will play a much more significant role as the primary point of contact for discussions on pay transparency.
A third striking finding is that, for the time being, organisations are clearly opting for cautious rather than full pay transparency. In job ads, 53% would definitely provide a general, qualitative description of their pay policy (such as ‘competitive’), but only 19% would definitely publish a specific salary range. For even more precise information, this figure drops further to 14% for the midpoint of a salary band and 13% for a reference salary. Moreover, 66% say they would only publish a salary range if legally required to do so. Willingness to embrace pay transparency thus drops sharply as soon as organisations are required to communicate specific figures.
Pay transparency should not be limited to a mere compliance project: it offers a unique opportunity to think strategically about how you communicate about pay in general and employee benefits in particular. The key question here is: what information is essential for employees to fully assess the value of their remuneration package – and to gain the (well-founded) sense that they are being fairly compensated?
As employee benefits specialists, our tip for when you start addressing pay transparency within your organisation is this: don’t forget to include your supplementary pension plans in your thinking!
For more information, see also our previous newsletter:
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