Salary ranges in job ads: what the EU Pay Transparency Directive changes for employers

If you’ve ever written “salary depending on experience” in a job ad, or opened a first call with “so what are you on at the moment?”, this one is for you. Both are on their way out.

Directive (EU) 2023/970 on pay transparency had to be transposed into each member state’s law by June 2026, and much of what it requires shows up right in the hiring process. Below is what we think matters most for a company that is hiring in Spain. Treat it as general guidance rather than legal advice: the final detail depends on the Spanish transposition law and its implementing rules, so check your own situation with an employment lawyer.

Where this comes from

The directive aims to strengthen equal pay between women and men for the same work or work of equal value. Its tool is transparency: giving candidates and employees enough information to spot pay differences that can’t be justified by objective criteria.

Spain isn’t starting from scratch. There is already the pay register (registro retributivo), which applies to every company, and the pay audit for companies that must have an equality plan. The directive builds on that framework and, above all, makes it far more visible.

What changes when you open a role

For employers, some of the changes are felt from day one.

Candidates are entitled to know the starting pay or the range for the role, based on objective, gender-neutral criteria. You can put it in the published ad or share it before the interview, but they need to have it before they sit down with you.

You also won’t be able to ask about current or previous pay. That includes the application form, where a “current salary” field still sits on plenty of careers pages without anyone remembering it’s there.

And job ads and job titles have to be gender-neutral, with a selection process that doesn’t discriminate.

In practice, the money conversation no longer opens with “what are you earning now?”. It opens with “this is the range for the role”.

And what changes for the people you already employ

The directive doesn’t stop at recruitment. It also affects what you tell your existing team. Among other measures, it provides for:

• Employees being able to see the criteria used to set pay and pay progression.
• The right to request information on their own pay level and on average pay levels, broken down by sex, for people doing the same work or work of equal value.
• A ban on contract clauses that stop workers from disclosing what they earn.
• Periodic gender pay gap reporting for companies above a certain size, on a staggered timetable depending on headcount.
• A joint pay assessment with employee representatives when reporting shows a significant gap that can’t be justified by objective criteria and isn’t corrected within the set period.

On top of that, there is a significant shift if someone brings a claim: it will be up to the employer to prove there has been no discrimination.

The awkward question a salary range brings up

Publishing a range looks like a matter of putting two numbers in an ad. In reality it forces you to answer questions many companies have been putting off for a while. Do you have a structure of roles and levels, or was each salary negotiated on its own at the time? Could you explain why two people in similar roles are paid differently?

The trickiest one is different. What happens if the range for a new opening sits above what someone already on the team earns? We run into this more often than you’d think, especially in tech roles, where the market moves quickly and internal salaries don’t always keep up. It’s far better to spot it and decide what to do before you publish than to find out because that person has seen the ad.

Where to start

If you haven’t done this groundwork yet, this is the order we usually suggest:

1. Map your roles and group them into families and levels based on responsibility, complexity and requirements. Think about the role, not whoever holds it today.
2. Write down the objective criteria that drive pay, such as relevant experience, level of responsibility or the impact of the role.
3. Build a range for each level using market benchmarks and your internal reality. Too wide and it tells nobody anything; too narrow and you lose room to manoeuvre.
4. Review current differences and plan how to correct the ones you can’t justify with those criteria.
5. Update job ads, first-call scripts, application forms and offer letters, and train your interviewers so they know what they can ask and how to talk about the range comfortably.

Talking money without the current-salary shortcut

Plenty of teams use current salary as their negotiating anchor because it’s convenient. Take it away and the conversation changes, and in our experience it usually changes for the better. You share the range, ask the candidate what they’re expecting and explain what puts someone higher or lower within it. From there you can talk about the whole package, from bonus and benefits to flexibility and learning.

It’s a more honest conversation for both sides, and it heads off a lot of surprises at the final stage, which is exactly where losing a candidate hurts most.

What you gain by publishing pay

Compliance aside, publishing the range has an effect you notice quickly. The people who apply are the ones who fit what you’re offering, and processes stop falling apart at the end over money. It also says something about you as an employer: a clear range shows there’s thinking behind your salaries.

If you want a reality check on whether your ranges hold up for the tech and business profiles you’re about to hire, at Mimmic Talent we work with market benchmarks every day. Tell us about your case.