In a little under one year the European Union’s Pay Transparency Guidelines will come into effect, aiming to usher in reduced gender pay gaps, fair pay practices and empowered employees.

For HR leaders the changes go beyond risk and compliance obligations – a change in culture, realigning strategy and dozens of practical implications on training and documentation reviews, to name but a few.

But what’s the state of readiness among global HR leaders ahead of June next year?

WTW’s 2025 Pay Transparency Report canvassed 1,915 respondents globally to gauge levels of readiness and attitudes towards the EU Pay Transparency Guidelines, regardless of requirements based on geography.

Speaking exclusively to UNLEASH, Tamsin Sridhara, Global Lead Pay and Career Equity at WTW, says that employers are coming to the realization that “pay is no longer a secret.”

“At a time when anyone can gain insights on a company’s pay from third party sites, employers are deciding that they want to own that narrative,” Sridhara explains.

“The survey highlights that it is changing employee expectations alongside regulatory developments that is encouraging employers to be more transparent on pay.”

Here’s what you need to know:

Disclosing pay ranges is becoming the norm, just not outside Europe

WTW’s research indicates that one of the primary objectives of the legislation – normalizing clarity and disclosure of pay ranges – is becoming the norm.

The majority of companies are already sharing, planning to share or considering sharing information about pay at different job levels (86%), how individual base pay is determined and progresses (82%) and how pay ranges are designed and managed (74%).

Meanwhile, the survey also found that 27% of organizations are either already or planning to share pay ranges to prospective employees in all locations regardless of requirements, with a further 35% considering doing so.

More than one in three (38%) organizations are already sharing this information in all locations where required to do so, with 24% planning to do so and 23% considering doing so. Just 15% of companies in this group said they have no plans to comply.

However, while organizations within the European Union are moving towards transparency as standard, companies outside the region – particularly in the Americas – are less concerned.

WTW found that just 28% of EU respondents are neither planning nor considering communicating average pay levels, but that percentage jumps to 53% for non-EU respondents with operations within the EU.

It increases further among North American and Latin American respondents to 73% and 84% respectively, indicating that there is still a long way to go before the guidelines are implemented on a global basis.

This may be of concern to HR leaders when considering talent acquisition and culture, where the expectations of prospective and existing employees on pay transparency are not being met.

Manager readiness and employee pushback are the biggest obstacles

While many organizations are seeking to enact more transparency around pay programs, there are various barriers impeding progress.

WTW’s research found that respondents believe more transparency and communication on pay ranges will result in more questions about compensation by employees (72%) and managers (69%) alike.

Meanwhile, 60% said they are anticipating an increase in pay negotiations with employees as a result of higher transparency.

These concerns also extend to organizations that are holding off on increased pay program communications, with just over half (53%) concerned over potential employee reactions and half (50%) over manager’s abilities to explain compensation programs.

Beyond other issues cited, such as administrative complexity, data availability and legal concerns, respondents also highlighted a concern over a lack of support from leadership when it comes to increased pay conversations.

While leaders and managers are the groups that are currently being educated or receiving the most training on pay (45% and 38% respectively), WTW’s findings illustrate clear concern over potential blowback from employees if transparent communications are implemented without the necessary preparation.

HR leaders will need to be at the forefront of education initiatives that both inform leaders of the strategic and long-term implications of transparency compliance, while arming managers with the skills, knowledge and tools to conduct effective communication with employees.

Pay transparency strategies shaped by more than just compliance

While compliance was the primary driver for increased communications around pay, as stated by 67% of respondents, WTW found there were other forces at work.

Nearly half of respondents (44%) highlighted company values and culture as one of the main drivers encouraging increased levels of communication, followed by an ESG/DEI agenda (41%), employee expectations (41%) and HR’s confidence in pay programs (37%).

In order to effectively measure the impact of pay transparency requirements, two thirds (66%) of organizations are using metrics to measure factors such as adjusted and unadjusted gender pay gaps, gender pay gaps relative to peers, and changes in gender pay gaps.

However, organizations are not yet turning to AI to help develop strategy and action when it comes to pay transparency, instead preferring to stick with what the research labels conventional technology.

Just 17% of respondents said they are currently using or planning to use AI for pay information communication or market competition research, compared to 23% 42% respectively using conventional technology.

While compliance will be a driver for HR leaders, it can also be viewed as an opportunity – defining strategy and drivers of success will enable organizations to not only get ahead of regulatory risk, but embed positive culture and communication standards, while ensuring employee expectations are not underestimated or neglected.