EU Pay Transparency for Non-EU Banks Opening Branches Under CRD VI
CRD VI Puts Your Branch in the EU. Pay Transparency Starts With Its First Job Ad.
From 11 January 2027, a non-EU bank offering core banking services in a Member State needs an authorized branch there, unless an exemption applies. Under each country’s pay transparency law, the branch’s hiring is in scope from its first job ad: candidates learn the pay before they negotiate, pay history stays off the table, and pay rests on criteria you can defend.
Europe HR Solutions builds the branch’s pay structure, pay ranges and hiring process for each branch country, in line with your group reward framework. Your first offer is built to comply, and your pay data is ready when reporting starts.
11 Jan 2027
WHO WE ARE
The Reward Partner That Builds Branch Pay for Local Law
Pay bands built for head office rarely hold up under a branch country’s pay transparency law. We design compensation and benefits frameworks country by country. In-country HR consultants cover local pay practice, and a senior team in Belgium holds every branch to one group standard.
Client story: Cold Jet, a US-based leader in dry ice technology, needed one HR approach across six European countries. Alongside contracts, policies and handbooks, we supported the harmonization of its compensation and benefits structures, and we remain its retained HR partner in Europe.
Read the Cold Jet story
TWO RULEBOOKS, ONE BRANCH
Two Regulatory Clocks. One Hiring Plan.
CRD VI decides when the branch must exist. The Pay Transparency Directive decides how it hires and pays from day one. The two run on separate timetables, so the pay framework has to be ready before the first hire.
Directive (EU) 2024/1619, third-country branches
11 July 2026
PassedGrandfathering cut-off. Contracts entered into before this date keep their protection. Contracts signed on or after it don't.
11 January 2027
The deadlineArticle 21c applies. Core banking services need an authorized branch in the Member State, unless an exemption applies, such as reverse solicitation, services to other banks, or intragroup services.
Directive (EU) 2023/970, every employer in the EU
7 June 2026
PassedTransposition deadline. By September 2026, five Member States had transposed the Directive. Each country's rules apply from its own date.
7 June 2027
First reportsFrom 150 workers, employers send in their first pay gap report, based on 2026 data.
Your first job ad and first offer
Your first job ad and first offer
Employer readinessIn each branch country, once its pay transparency law takes effect, the pay information duty, gender-neutral job ads, the no-pay-history rule and transparent pay criteria cover the first hire, whatever the headcount.
Dates checked 19 October 2026 against the Directives as published in the Official Journal. National dates and thresholds depend on each Member State's law.
WHAT APPLIES WHEN
Too Small to Report, Not Too Small to Comply
Most new branches open with a small team. That keeps them out of pay gap reporting for a while, but not out of the Directive. Its hiring and pay-setting rules apply to every employer from the first vacancy.
Every branch, whatever its headcount
Once its country's rules take effect.
- Starting pay or pay range shared early enough to negotiate, plus any relevant collective agreement terms Article 5
- No questions about current or past pay Article 5
- Gender-neutral job ads and job titles, and a non-discriminatory recruitment process Article 5
- Pay structures built on objective, gender-neutral criteria: skills, effort, responsibility and working conditions Article 4
- The criteria behind pay, pay levels and progression made easily accessible to workers Article 6; countries may exempt employers under 50 from the progression part
- Written replies within two months to workers who ask for their own pay and the average pay of women and men in the same or equal-value roles, plus a yearly reminder of this right Article 7
- No contract terms that stop workers from disclosing their pay Article 7
Only once the branch grows
Reporting starts in stages, and a branch country can set a lower threshold.
- 250+ workers: report due by 7 June 2027 and every year after Article 9
- 150 to 249 workers: due by 7 June 2027, then every three years Article 9
- 100 to 149 workers: due by 7 June 2031, then every three years Article 9
- A joint pay assessment with worker representatives when a category shows an unjustified gap of at least 5% that stays unfixed for six months Article 10
- Member States can require smaller employers to report as well
How a branch's headcount is counted is a question of national law, including whether staff of other group entities in that country count with it. We confirm it per branch country, with your counsel.
ONE DIRECTIVE, UNEVEN NATIONAL LAWS
One Directive. A Different Pay Transparency Law in Every Branch Country.
The Directive sets the floor. Each Member State writes the detail: how pay ranges are shared, how reporting works, who counts as a worker and what the penalties are. Your branch follows the law of its country, at whatever stage that law has reached.
Transposition status as of September 2026
Germany
- The 2017 Pay Transparency Act already gives employees in establishments with more than 200 staff a right to pay information. No government bill had reached cabinet by the end of September 2026.
France
- Employers with 50 or more employees already publish a gender equality index every year. The draft law replaces it with new pay indicators and was amended on 10 September 2026 before going to Parliament.
Netherlands
- The bill went to Parliament on 21 May 2026. Plenary debates are set for December 2026 and January 2027, so the 1 January 2027 target is uncertain.
Ireland
- Gender pay gap reporting already applies from 50 employees. A separate Pay Transparency Bill is planned but did not get priority drafting status in September 2026.
Luxembourg
- No transposition bill yet. The Labor Code already requires half-yearly statistics by gender, including on pay, for the staff delegation and the equality delegate.
Italy
- Legislative Decree 96/2026 has applied since 7 June 2026. Candidates must receive the starting pay or its range, and national collective agreements are the main reference for work of equal value.
These markets are illustrations, not country-specific legal advice. Statuses are checked against national transposition trackers before publication.
Six branch countries means six pay transparency laws, run as one coordinated pay framework, not six local projects.
WHAT EUROPE HR SOLUTIONS HANDLES
Pay Transparency for Non-EU Bank Branches, Built Country by Country
Six workstreams for every branch country, drawing on our Compensation & Benefits Strategy, Systems & Payroll Coordination and Retained HR Services, so the branch opens with pay that is compliant, explainable and ready to report.
Pay Structure & Banding
Job architecture, grading and pay bands for the branch, built on objective, gender-neutral criteria, benchmarked locally and aligned with your group reward policy.
Pay Ranges in Job Ads & Offers
A starting pay or range set for every role before it is advertised, gender-neutral job titles, and an offer process with no pay history questions.
Pay-Setting & Progression Criteria
Written criteria for pay, pay levels and progression that workers can access, documented per country.
Worker Information Requests
A process and templates for answering individual and average pay requests within each country’s deadline.
Pay Data & Reporting Readiness
HR and payroll data set up with your payroll provider by category of workers from the first hire, so reporting is ready when the branch reaches the threshold.
Ongoing Pay Compliance
Each country’s law, thresholds and reporting dates tracked after opening, with ranges, criteria and policies updated as the law moves.
WHY ONE EUROPEAN PARTNER
Local Pay Rules. One Coordinated Pay Framework.
Each branch country adds its own law on top of the Directive. We bring the local work together, so your reward team sees one framework and one status across the whole CRD VI program.
Country-by-country pay projects
Separate reward, legal and recruitment advisers in each Member State.
- Pay ranges set differently in every branch
- A different reading of what a pay range must show
- Job ads and offers checked after they go out
- Pay data in formats that don't match
- Head office reconciling pay by hand
- Thresholds and reporting dates tracked by no one
One European HR partner
Local pay expertise, coordinated by Europe HR Solutions.
- One pay framework, localized per country
- One method for setting and sharing pay ranges
- Job ads and offers compliant before they go out
- Pay data structured once, ready to report
- One view for reward, HR and leadership
- A clear owner for every pay transparency duty
HOW WE RUN IT
Map. Band. Publish. Prepare.
Four steps per branch country, timed to your hiring plan, so pay is settled before the first role goes live.
Map
Branch roles, group reward policy and local pay practice checked against each country's law and the thresholds that apply to your branch.
›Band
Pay structures and ranges built per country on objective, gender-neutral criteria, benchmarked locally and aligned with your group framework.
›Publish
Pay ranges, job ad and offer templates, and pay criteria ready in the required form before the first vacancy is advertised.
›Prepare
Pay data structured from the first hire, so information requests and reporting are answered on time.
PART OF OUR CRD VI SERIES
More Support for Your CRD VI Branch
Market Entry HR Setup for Third-Country Branches →
The employment foundation for opening the branch — management, key function holders and local HR, built per Member State.
CRD VI · BankingEmployment Documentation for Third-Country Branches →
Every contract, policy and handbook a branch employee needs, written for local law.
CRD VI · BankingSystems & Payroll Coordination for Third-Country Branches →
Multi-country payroll, employee data and HR systems, coordinated into one European operating model and reporting into one place.
QUESTIONS BANKS ASK US
Pay Transparency for CRD VI Branches: Your Questions Answered
1. Does the Pay Transparency Directive apply to a branch with only a few employees?
Yes, for hiring and pay setting. Every employer must tell candidates the starting pay or pay range, avoid pay history questions, base pay on criteria that are objective and gender-neutral, and answer workers’ requests for pay information. Only gender pay gap reporting waits until 100 workers, and some countries set a lower bar. How a branch is counted is a national-law question, so we confirm it per country with your counsel.
2. Do we have to put a pay range in every job ad?
Not necessarily. The rule is about timing: each candidate must learn the starting pay or pay range early enough to negotiate. The Directive names the job ad or the stage before the interview as examples, and each Member State sets the exact form. Where a collective agreement applies, its relevant terms are shared too. Ads and job titles must be gender-neutral, and pay history questions are off limits. A range in every ad is the simplest way to comply in every branch country.
3. Our group pay bands are set in London or New York. Can the branch use them?
Yes, as a base. Rarely as the published range. Each branch range has to fit the role in that Member State, in local currency, benchmarked to the local market and based on criteria you can show are objective and gender-neutral. We translate your group bands into a local structure per country and document the reasoning.
4. When do we have to report our gender pay gap?
It depends on headcount. At 250 workers or more, the first report is due by 7 June 2027 and then yearly. At 150 to 249, it is due by the same date and then every three years. At 100 to 149, the first one is due by 7 June 2031. Every report covers the year before it is filed. Member States may introduce reporting obligations for employers with fewer than 100 workers. Set up your pay data from the first hire, so the branch is ready when it crosses one.
5. Does CRD VI grandfathering change anything for pay transparency?
No. Article 21c(5) protects banking contracts entered into before 11 July 2026. It does not cover employment. Branch staff fall under that country’s employment and pay transparency rules from their first day.
6. Only a few Member States have transposed the Directive. Should we wait?
No. Five had transposed by September 2026, and the rest are still required to. Building to the Directive now and adjusting as each national law lands costs less than rebuilding ranges and job ads after your first hires. We track every branch country and tell you what changes.
7. How do you work with our counsel and remuneration committee?
We build the HR and reward side: pay structures, ranges, job ad and offer templates, pay criteria and the data behind reporting. Your counsel reviews the legal positions, your remuneration committee keeps ownership of pay policy, and our work stays within the remuneration rules that already apply to the bank.
8. How long does it take to prepare several branch countries?
It depends on the number of countries, the roles in scope and how developed your group pay architecture is. Our compensation projects typically take four to six weeks, and multi-country scopes usually six to eight weeks or longer. We run the countries in parallel, against your branch opening dates.
Reviewed by Nadia Harris, Client Solutions Director · Last reviewed October 2026
Set Your Branch Pay Before You Post the First Role
Know What Each Branch Must Show at Hiring
Tell us your branch countries, first roles and opening dates. We map what each country’s pay transparency law requires at the hiring stage, and what starts later.
You get a per-country view of the pay range, job ad, offer and information duties, with the thresholds that apply to your branch.
No commitment, just a clear list of what to settle before the first offer.