Legislative developments creating new pay transparency and disclosure obligations will lead to a considerable number of new tasks to be attended to internally, particularly for firms with a workforce of one hundred or more. As we have been reporting each week, the tasks that await include a complete review of the pay structure, responding to queries from employees on pay levels for their employee category, and compiling information regarding the pay gap to be submitted to the competent authorities. 

It would be advisable to begin considering now who within the organisational structure will perform these tasks on the employer’s behalf?

The directive does not address this issue, and does not require positions or internal units to be created to take charge of compliance with the pay transparency and disclosure obligations.

While this may mean that employers are free to resolve this as they wish, it would be unwise to wait with determining who will be responsible for coordination and performance of the new tasks on the employer’s behalf, as the new obligations are to be in place by 2026. In the larger firms – where this could trigger a considerable workload – it might be particularly useful to designate a new, separate position, or carry out a meticulous review of responsibilities within the HR department to streamline the mechanisms for compliance with the forthcoming legislative changes.