EU Pay Transparency Directive: What Every IT Staffing Firm Must Do Before June 2026

38.4% of IT Staffing Firms Are Not Ready. Are You?

In less than three months, EU Directive 2023/970 on pay transparency will take effect for all companies with more than 100 employees. Yet, according to a survey by Syntec Numérique in early 2026, 38.4% of French IT staffing firms have not started any compliance work.

This is not a cosmetic issue. It affects job postings, recruitment interviews, salary grids, annual reports, and potentially employment tribunals. For IT staffing firms, whose compensation structures are notoriously complex, this is a turn that must be navigated without error.

This article covers what the directive actually requires, why IT staffing firms are particularly exposed, and the five concrete workstreams to launch immediately.

What the Directive Actually Requires

Directive 2023/970/EU, adopted on May 10, 2023 by the European Parliament, is built on three pillars.

First pillar: transparency at hiring. Candidates now have the right to know the salary range for the position before the first interview. The company must communicate this information proactively, either in the job posting or at the latest before the interview. It is also prohibited to ask candidates about their salary history. Second pillar: employees' right to information. Any employee can request average pay levels, broken down by gender, for categories of workers performing identical or equivalent work. The employer has two months to respond. Third pillar: mandatory reporting. Companies with more than 250 employees must publish an annual detailed report on gender pay gaps. For companies between 100 and 249 employees, the report is triennial. If an unjustified gap of more than 5% is found and not corrected within six months, the employer faces sanctions.

Regarding sanctions, the directive lets member states set the amounts but requires they be "effective, proportionate and dissuasive." France is preparing an implementation decree that should include fines of up to 1% of annual payroll, as well as damages for affected employees, with reversal of the burden of proof: it is the employer who must prove there is no discrimination.

Why IT Staffing Firms Are Particularly Exposed

Most large corporations already have structured salary grids, detailed collective agreements, and standardized HR processes. IT staffing firms, however, accumulate several risk factors.

Job titles that mask very different realities. A "senior consultant" can mean a profile at 42,000 euros gross annually in a mid-sized regional firm, and a profile at 62,000 euros in a Paris-based firm positioned on high-value consulting. Same title, 48% gap. This is exactly the type of situation the directive targets. A historical culture of salary opacity. In many IT staffing firms, consultant salaries are not shared internally. The daily rate (TJM) is known, but actual consultant compensation remains taboo. This culture of secrecy directly conflicts with the spirit of the directive. Structural gender pay gaps. The 2025 Syntec barometer indicates an average pay gap of 12.7% between men and women in the digital sector, for comparable positions. This exceeds the national average (11.6%) and is well above the 5% threshold that triggers the correction obligation. High recruitment volume. IT staffing firms with 100+ employees publish an average of 45 job postings per month. Each one must now include a salary range. This is a massive operational change for recruitment teams.

The 5 Workstreams to Launch Before June 2026

Workstream 1: Complete Salary Data Audit

Before publishing anything, you need to know where you stand. This means mapping all compensation by job category, gender, seniority, and location. The goal is to identify gaps and distinguish justified ones (experience, rare skills, geographic area) from unjustified ones.

In practice, this is often the heaviest workstream. Salary data is scattered across HRIS, manager spreadsheets, payroll software, and sometimes ERP. Everything needs to be centralized, cleaned, and cross-referenced.

Workstream 2: Job Description Overhaul

The directive requires comparing pay for "workers performing identical or equivalent work." This assumes having precise, up-to-date job descriptions that genuinely reflect work content.

In an IT staffing firm, this is a particular challenge. A "fullstack developer" might work on an application maintenance project billed at 450 euros/day or on a cloud architecture mission billed at 900 euros/day. If the job description is identical, the salary gap will appear unjustified.

Workstream 3: HR and Recruitment Tooling

Compliance cannot rely on manual processes. You need a tool that can store salary ranges by position, associate them with job postings, track offers made to candidates, and generate regulatory reports.

Specifically, your ATS must be able to integrate a "salary range" field on each posting, make it visible to candidates, and archive data for reporting.

Workstream 4: Internal Communication

Salary transparency is a cultural change as much as a regulatory one. Employees will discover information they didn't have. Some will notice gaps. Others will question their own positioning.

It is essential to prepare this communication in advance. Explain the approach, set the framework, acknowledge identified gaps, and present the correction plan.

Workstream 5: Manager and Recruiter Training

Frontline managers and recruiters will be first in line. They will need to answer candidate questions about salary ranges, justify compensation offers, and handle employee information requests.

A recruiter who asks "What is your current salary?" in an interview now exposes the company to direct legal risk.

What This Concretely Changes in Recruitment

The most immediate impact concerns job postings. Each listing must mention a salary range. This is a radical change for a sector where "salary based on profile" was the norm.

For IT staffing firms, this means defining the salary range for each open position upfront, validating it with management, and integrating it into the job publishing tool. Candidates will be able to compare offers not just on mission content but on proposed compensation. Transparency will become a direct competitive advantage in the war for talent.

Interviews change too. The prohibition on asking for salary history forces recruiters to evaluate candidate value independently of what they earned before.

Finally, each salary proposal must be consistent with the published range and with the compensation of current employees in similar roles.

Preparing Compliance With the Right Tools

Compliance with the pay transparency directive is a cross-functional project touching HR, recruitment, management, and finance. It largely depends on the ability to centralize, structure, and leverage compensation data.

Cobalt was built for IT staffing firms and recruitment agencies. The platform centralizes job descriptions, candidate history, placement data, and salary information in a single workspace. Each job posting can integrate a salary range visible to candidates. Each offer is tracked and archived.

The June 2026 deadline is no longer a distant horizon. It is three months away. IT staffing firms that have not yet started their compliance work are taking a regulatory, reputational, and competitive risk. Those who act now will have not only avoided sanctions but transformed pay transparency into a competitive advantage.

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Sources: Directive 2023/970/EU of the European Parliament and of the Council of 10 May 2023. Syntec Numérique Barometer 2025. Syntec Numérique survey on IT staffing firm readiness for pay transparency, January 2026.