CRD VI Brings Your People Into the EU. Pay Transparency Applies to Them From the First Job Ad.

For the hiring and pay-setting rules, yes. Every employer has to give candidates the starting pay or its range, stop asking about pay history, set pay on objective and gender-neutral criteria and answer workers who ask about pay levels. Only the gender pay gap reporting starts at 100 workers, and some Member States set that bar lower. How a branch of a non-EU bank is counted, and whether staff of other group entities in the same country count with it, is decided by national law, so we confirm it per branch country with your counsel.

Candidates must receive the starting pay or its range before the interview. The Directive allows it in the vacancy notice or in another way before the interview takes place, and each Member State decides the exact form. Job ads and job titles have to be gender neutral, and the branch may not ask candidates what they earn now or earned before. In practice most banks put the range in the ad, because that is the simplest rule to apply in every country.

As the starting point, yes. As the published range, rarely. The branch range has to be expressed for the role in that Member State, in local currency, benchmarked to the local market and built on criteria the branch can show are objective and gender neutral. It also has to stay consistent with the remuneration policy described in your authorization file. We translate the group bands into a per-country structure and document the reasoning, so reward keeps one framework and every branch has a defensible local version.

Employers with 150 workers or more report for the first time by 7 June 2027, on 2026 pay data. Employers with 250 or more then report every year, those with 150 to 249 every three years, and those with 100 to 149 report for the first time by 7 June 2031. Member States may set lower thresholds. A new branch is usually well below 100 workers on opening day, but the data has to be structured from the first hire, because the first report covers a full calendar year.

No. The grandfathering in Article 21c(5) concerns contracts for banking services entered into before 11 July 2026, not employment. The people a branch hires fall under the employment law of that Member State and its pay transparency rules from their first day, whatever the status of the bank’s client contracts.

No. By the 7 June 2026 deadline only a handful of Member States had fully transposed, but every branch country will have its own law in force, and branches that open in 2027 will hire into it. Building the pay framework to the Directive now, and adjusting it to each national law as it lands, is cheaper than rebuilding ranges and job ads after the first hires. We track the status of every branch country and tell you what changes.

No. We build the HR and reward framework: pay structures, ranges, job ad and offer templates, the pay-setting criteria workers can see, and the data model behind reporting. Your counsel reviews the legal positions and your remuneration committee keeps ownership of pay policy. We work alongside both and keep the regulatory remuneration rules that already apply to the bank in view.

Yes. One team runs every country against your hiring plan, using one pay framework localized per Member State, so each branch has its ranges, templates and criteria ready before its first vacancy. Timing depends on the number of countries, the roles in scope and how far your group pay architecture already goes, and we set the plan against your branch opening dates.