EU Pay Transparency for Fast-Growth E-Commerce

Pay Set Market by Market Won't Hold Up Under Pay Transparency. Build One Framework Before the Gaps Show Up.

Fast-growth e-commerce sets pay the way it hires: quickly, market by market and team by team. Warehouse rates follow the local agency, customer service pay follows the language you needed that month, and HQ and tech offers follow whoever you were trying to win. Under the EU Pay Transparency Directive, each of those numbers needs a range, written criteria and an explanation an employee can ask for.

Europe HR Solutions builds one pay framework across your role families and markets: job architecture, pay ranges and objective criteria that hold up in job ads, pay requests and pay reports, before the gaps show up.

Illustrative · one role, one country
Customer service agentSame role · same entity
Launch teamHired in year one
Peak-season hiresHired fast, paid to fill
Hired this yearMatched to new offers
Pay range in useTypical offer
Three pay points for the same work and no written criteria behind them.
Job ad rangeWhich one?
Pay requestUnexplained
Pay reportGap risk

WHO WE ARE

Pay Specialists Who Know How Warehouses, Contact Centers and HQ Teams Are Paid

Pay transparency often lands with lawyers, or with a reward consultancy that has never run a warehouse. We work on both sides: in-country HR specialists who know how fulfillment, customer service and HQ teams are paid in each market, and a central team that turns it into one framework your People team can run. One senior team based in Belgium, specialists across Europe, and the same method for every market you add.

(Placeholder) One-line client story comes with Frane's copy. To confirm with Alexis: MNX Global Logistics is the closest workforce profile.
250+Companies supported
27+European countries
15+Years of experience
50+In-country consultants

WHERE PAY DRIFTS

One Business, Three Workforces, and Pay That Drifts in Each

Fulfillment, customer service and HQ roles are hired on different clocks and paid on different logic. Spread that across four markets and the same business ends up with a dozen pay stories.

Role family
Germany
Netherlands
Poland
Spain
Fulfillment & warehouseShifts, peak season, agency conversion
Shift premiums differ by site
Range with written criteria
Agency rates carried over
Peak bonuses set case by case
Customer serviceLanguages, channels, outsourcing
Language premium never written down
In-house and outsourced pay mixed
Range with written criteria
Set offer by offer
HQ & techOffers, equity, competition for talent
Negotiated offer by offer
Bands copied from another market
Negotiated offer by offer
Range with written criteria
IllustrativeRange with written criteriaRange, but no criteriaSet offer by offer
The Directive compares pay within each employer, so every country entity needs a structure it can explain. One framework keeps them consistent as you add markets.

REPORTING THRESHOLDS

Growth Crosses Reporting Thresholds Faster Than Pay Policies Change

Pay gap reporting starts at 100 workers and tightens at 150 and 250. A fast-growing entity can climb through two bands before anyone has rewritten the pay policy.

100
150
250
Your headcount as you grow
Under 100 workersNo pay gap report

Job ad, pay criteria and pay request rules still apply. Countries can go further.

100 to 149Every three years

First report by 7 June 2031

150 to 249Every three years

First report by 7 June 2027

250 or moreEvery year

First report by 7 June 2027

Counted per employerThresholds apply to each employing entity, so a new country entity starts its own count.
Previous calendar yearEach report covers the year before it is due, so the first reported year is already underway.
Peak season moves the lineA strong peak or a new fulfillment site can take an entity past a threshold in one hiring wave.

Source: Directive (EU) 2023/970, Article 9. National laws set the details of how workers are counted.

WHERE THE RULES APPLY

From Job Ad to Pay Report: Where the Directive Touches Pay

Pay transparency is not one deadline. It shows up at five points in the life of a role, and the first two happen every time you hire.

1Job ad

Starting pay or its range, and a gender-neutral title and description.

Article 5
2Interview

The range shared in time to negotiate, and no questions about pay history.

Article 5
3Pay request

Workers can ask for their pay level and average pay by sex for the same work or work of equal value. You answer within two months.

Article 7
4Pay report

Gap figures by category of workers, once an entity reaches 100, 150 or 250 workers.

Article 9
5If neededJoint pay assessment

If a gap of 5% or more in a category is not justified by objective criteria and not fixed within six months.

Article 10

COUNTRY STATUS

Where Your Main Markets Stand on Transposition

Each Member State writes the Directive into its own law, so your markets move at different speeds and with different details. We track them for you and build to the strictest version you operate in.

As of October 2026(Placeholder) Statuses come with Frane's copy.
DE
GermanyTo come
FR
FranceTo come
NL
NetherlandsTo come
ES
SpainTo come
IT
ItalyTransposed
PL
PolandTo come
BE
BelgiumTo come
IE
IrelandTo come
TransposedDraft lawInitial stepsNo activity yet

WHAT EUROPE HR SOLUTIONS HANDLES

EU Pay Transparency Compliance for E-Commerce, Workstream by Workstream

Six pieces of work that turn pay set in a hurry into a framework you can publish, explain and report on, in every market you operate in.

(Placeholder) Final card titles and wording come with Frane's copy.

Job Architecture Across Role Families

Every role in fulfillment, customer service and HQ placed into families and levels, so equal work is compared the same way in every market.

Pay Ranges by Role and Market

Ranges for each level in each country, built from your own pay data and local benchmarks, ready to publish in job ads.

Objective Pay Criteria

Written, gender-neutral criteria for pay and progression, including shift premiums, language allowances and peak-season pay.

Pay Gap Analysis Before the First Report

Your data run the way a report will run it, by category of workers, so gaps are found while there is still time to explain or fix them.

Job Ads, Offers and Pay Requests

Templates and a routine for ranges in job ads, interview scripts without pay-history questions, and answers to pay requests within two months.

Reporting and Joint Pay Assessment Readiness

Report-ready data per entity, a remediation plan with costs and dates, and preparation for a joint pay assessment if one is triggered.

HOW IT WORKS

Group. Range. Justify. Track.

Four steps, run country by country on one method, with your People, Operations and Finance leads in the room for the decisions that matter.

01Group.

Every role across fulfillment, customer service and HQ sorted into job families and levels, compared on skills, effort, responsibility and working conditions.

You getOne job architecture for every market
02Range.

Pay ranges for each level in each country, built from your data and local benchmarks, so a job ad can carry a range you stand behind.

You getRanges you can publish
03Justify.

Written criteria for pay and progression, and a gap analysis that shows which differences you can explain and which need fixing.

You getCriteria and a costed fix list
04Track.

A routine for job ads, new hires, pay requests and reporting, so the framework holds as you add people, sites and markets.

You getReport-ready data every year

RELATED PAGES

Build the Pay Framework on a Workforce Model That Holds

WHAT PEOPLE TEAMS ASK US

EU Pay Transparency for E-Commerce Teams: Your Questions Answered

1. Does the EU Pay Transparency Directive apply to us if our headquarters is outside the EU?

If you employ people in an EU country, yes. The rules apply to each employer in the EU, which for most e-commerce groups means each local entity. Where you headquarter the business does not change the obligations of the entity that employs your warehouse, customer service or HQ staff.

2. What is a pay framework under pay transparency?

A pay framework is the set of job levels, pay ranges and written, gender-neutral criteria that decide what each role is paid and how pay progresses. The Directive requires employers to make the criteria for pay, pay levels and pay progression available to their workers, so the framework has to be written down and applied the same way to everyone. Countries may exempt employers with fewer than 50 workers from the progression part.

3. We have fewer than 100 workers in a country. Do we still need to act?

Yes. Pay gap reporting starts at 100 workers, but the rules on job ads and interviews, the pay criteria and the right of workers to ask about pay apply to every employer, whatever its size. Countries can also extend reporting to smaller employers.

4. How can warehouse, customer service and HQ roles fit into one framework?

The Directive compares pay for the same work and for work of equal value, assessed on skills, effort, responsibility and working conditions. Roles in different families can be of equal value, so one framework measures them on the same criteria. Shift premiums, language allowances and peak-season pay can stay, as long as the reason for each is written down and applied consistently.

5. When is our first pay gap report due?

It depends on headcount per employer. Entities with 250 or more workers report every year and those with 150 to 249 every three years, both for the first time by 7 June 2027. Entities with 100 to 149 workers report every three years, for the first time by 7 June 2031. Each report covers the previous calendar year, and national laws set the details.

6. What happens if our report shows a gap of 5% or more?

If the gap in any category of workers is not justified by objective, gender-neutral criteria and is not fixed within six months of the report, the employer carries out a joint pay assessment with workers’ representatives. Finding the gap in your own analysis first leaves time to explain it or close it.

7. What can an employee ask us about pay?

Workers can ask for their own pay level and the average pay levels, broken down by sex, for workers doing the same work or work of equal value. You answer within two months at most, and you remind workers of this right every year. Contract clauses that stop employees from sharing their own pay are no longer allowed.

8. Our markets are at different stages. Which version of the rules do we follow?

Each country’s own law, for the entity that employs people there. The Directive sets the common floor, and Member States add their own details on timing, reporting and enforcement. We track each of your markets and build the framework to the strictest version you operate in, so one structure holds everywhere.

One Pay Framework for Every Role and Market, Before the Gaps Show Up.

See where your pay will drift before a report or a request shows it

Tell us your markets, your headcount in each and how your fulfillment, customer service and HQ teams are paid today.

We come back with which thresholds you will cross and when, where pay is most likely to drift, and the order to build the framework in.

No commitment required. Just a clear view of what pay transparency means for your workforce.