On 25 February, two of the JobMatchingPartner team, Frederick and Anneli, attended an EU Pay Transparency Directive workshop organised through the Malta Chamber, with insights delivered by RSM Malta and Ganado Advocates.

The session focused on the practical realities of the directive and its implications for employers operating in Malta and across the EU. While much of the conversation around the directive centres on legal compliance, the deeper shift is cultural and structural. Transparency is moving from being optional and discretionary to being embedded in how organisations recruit, benchmark, justify and communicate pay.

For employers and hiring teams, this is not a future issue. It is a planning issue.

The EU Pay Transparency Directive (Directive (EU) 2023/970) was introduced to strengthen the principle of equal pay for equal work or work of equal value between men and women. Member States must transpose the directive into national law by June 2026.

While the underlying principle of equal pay is not new, the enforcement mechanisms and transparency obligations represent a significant evolution.

Key elements include:

• The requirement to provide job applicants with information about initial pay or salary ranges before employment.

• Restrictions on asking candidates about salary history.

• The right of employees to request information about pay levels and criteria.

• Gender pay gap reporting obligations for employers with at least 100 workers, introduced in phases from 2027 onwards.

• Clearer enforcement mechanisms where unjustified gender pay gaps are identified, including the possibility of a mandatory joint pay assessment where reporting reveals a pay difference of at least 5% that cannot be justified by objective, gender-neutral criteria.

What becomes clear when listening to legal and advisory experts is that this is not merely an HR documentation update. It affects how roles are structured, how compensation frameworks are justified, and how recruitment conversations are conducted.

From JobMatchingPartner’s experience working with employers in iGaming, fintech, corporate services and financial services, we know many organisations in Malta can operate within an international labour market. Employers may hire across borders, benchmark against EU salary standards and compete with other remote opportunities across Europe..

In this environment, unclear pay practices are already under pressure from market forces. The directive formalises that pressure.

Organisations that rely on informal salary setting, ad hoc negotiation or inconsistent job grading will find that transparency exposes structural weaknesses. Employers that already operate with defined pay bands, documented criteria and aligned hiring processes will find the transition significantly smoother.

Because candidates are becoming more data-savvy, we encourage both employers and applicants to use our salary benchmarking tool to gain objective Malta salary insights before entering negotiations.

The workshop made it clear to all that preparation will determine whether implementation feels controlled or disruptive.

Recruitment is one of the first operational areas where the directive becomes visible.

While many organisations will include salary ranges directly within job advertisements as transparency becomes the norm, the directive allows employers flexibility in how and when this information is communicated, provided candidates receive it before the interview stage.  This ensures that negotiations take place with greater transparency. 

Candidates will therefore increasingly expect clarity before engaging in interviews. At JobMatchingPartner, we invite you to explore our current roles in Malta and the EU to see how we are already listing transparent job opportunities. Conversations that once revolved around “expected salary” without context will need to be reframed around structured, pre-defined compensation bands.

How Salary Information Can Be Provided Before the Interview

Under Article 5(1) of the Pay Transparency Directive, employers must provide candidates with information about the initial pay or salary range for a role before the interview stage. While many organisations may choose to include this information directly in job advertisements, the directive allows flexibility in how it is communicated.

Examples of compliant approaches include:

1. During the application stage
   Salary information can be shared on the application page once a candidate begins the application process, ensuring they understand the expected compensation before progressing further.

2. In an automated confirmation email
   After a candidate submits an application, employers may include the salary range or pay information within the automated confirmation email sent to applicants.

3. In recruiter outreach messages
   If a role is being sourced through direct outreach, the recruiter may provide the salary range when first contacting a potential candidate.

4. In a pre-interview information pack
   Employers may send a short briefing or information document to candidates invited to interview, outlining the role, responsibilities and salary range.

5. During an initial screening call
   Some organisations may communicate the salary range during the first screening discussion, provided this occurs before the formal interview stage.

Equally important is the prohibition on asking about salary history. Many hiring managers still use previous compensation as an anchor point for offers. That approach becomes legally and ethically problematic under the directive’s framework.

For recruitment partners, this introduces both responsibility and opportunity.

Responsibility, because recruiters must ensure that job descriptions, salary discussions and interview processes are aligned with evolving requirements. Opportunity, because employers navigating these changes will need informed guidance rather than generic candidate shortlists.

At JobMatchingPartner, recruitment already operates within structured market benchmarking and role-specific salary insights. The directive reinforces the importance of that discipline.

Beyond recruitment, the directive pushes organisations to confront broader compensation questions:

• Are pay bands clearly defined and documented?

• Are promotion and progression criteria objective and defensible?

• Can differences in pay between employees performing comparable work be justified with evidence?

• Are hiring managers trained to understand the new transparency standards?

The workshop discussions highlighted that many companies underestimate the importance of documentation. Transparency is not simply about publishing a number. It requires clarity around how that number was determined.

In sectors such as iGaming and fintech, where roles evolve quickly, and international competition influences salaries, maintaining internal consistency while remaining externally competitive demands careful alignment between HR, finance and leadership.

Recruitment sits at the hub of compliance, market benchmarking and employer reputation. As a specialist recruitment partner operating in Malta and across the EU, JobMatchingPartner works closely with employers in iGaming, fintech, corporate and financial services.

Following the insights gained from the Pay Transparency Directive workshop, our focus is on helping clients:

• Structure job specifications with clearly defined compensation parameters.

• Benchmark roles against realistic Malta and EU market data.

• Align hiring conversations with emerging transparency standards.

• Ensure recruitment workflows support defensible and objective decision-making.

We don’t see this as creating an administrative burden for ourselves, we prefer to look at it as strengthening our hiring foundations in a way that protects both employer and employee interests.