June 7, 2026 is the deadline for transposing EU Directive 2023/970 on pay transparency into French law. France will likely miss this deadline — the Labor Minister has acknowledged aiming for September 2026 at the latest for effective transposition. But whether the law arrives in June or September changes nothing for a staffing firm leader: the compliance work should have started eighteen months ago.
The numbers speak for themselves: only 6.2% of French companies currently have a formalized compliance project for this directive. In the staffing firm world, where HR functions are often reduced to the bare minimum and salary policy is managed "case by case," that percentage is probably even lower.
And yet, salary transparency isn't just another HR project you can handle alongside operations. For a staffing firm, it strikes at the heart of the business model: margins, daily rate negotiation, consultant and BM compensation policies, employer attractiveness, the ability to recruit and retain. Anticipating means protecting your profitability. Being caught unprepared means losing it.
This article details the directive's concrete obligations, explains why staffing firms are more exposed than the average company, measures the impacts on the business model, and proposes the four projects to launch now.
What the Directive Concretely Requires
Directive 2023/970 is an ambitious text that goes well beyond what most leaders imagine. Here are the seven main obligations that staffing firms will need to comply with, summarized operationally.
First obligation: every job posting must include a salary range, communicated to the candidate before the first interview or directly in the listing. This applies to BM recruitment, internal consultants, salespeople — every salaried position.
Second obligation: it becomes illegal to ask about salary history. The question "what were you earning at your previous employer?", extremely common in staffing firms for calibrating packages and daily rates, becomes unlawful.
Third obligation: any employee may request to know the average pay levels for their position or an equivalent one, broken down by gender. The employer has two months to respond with documentation.
Fourth obligation: regular reporting of gender pay gaps will be required. Annually for firms with 250+ employees, every three years for those with 150 to 249. And starting in 2031, the threshold drops to 100 employees — mid-sized firms are not exempt long-term.
Fifth obligation: if a pay gap greater than 5% between men and women is found without objective justification, the firm must conduct a joint assessment with employee representatives and correct it.
Sixth obligation: the burden of proof is reversed. If an employee claims pay discrimination, it's up to the firm to prove it didn't discriminate — not up to the employee to prove they were discriminated against.
Seventh obligation: salary confidentiality clauses become prohibited. Employees can freely discuss their pay with each other, with no contractual clause preventing them.
For the first time, salary confidentiality becomes illegal. And in a staffing firm, where everything revolves around differentiating daily rates and packages, that changes everything.Why Staffing Firms Are More Exposed Than Average
All French companies are affected by this directive, but the staffing firm model concentrates risks disproportionately. For five sector-specific reasons.
The first is that packages are extremely variable from one consultant to another, even at equivalent positions. In a typical firm, two consultants with the same job title and seniority level can have salaries differing by 20 to 30%, simply because one negotiated better at hiring, or was recruited during a tight market period. Some of these gaps are objectively justifiable — rare skills, specific certification, industry experience. Others aren't. And the directive requires every gap to be justified objectively and with documentation.
The second reason is that variable pay weighs heavily in staffing firm compensation. Mission bonuses, supplements tied to the billed daily rate, end-of-project bonuses, non-bench bonuses: variable pay represents 15 to 30% of a consultant's total package. Yet the rules for calculating these variables are often vague, communicated verbally, or documented only in internal presentation slides pulled out once a year. Transparency will force every variable component to be formalized with objective, communicable criteria.
The third reason is the information asymmetry between BMs and consultants. Today, Business Managers know the daily rates billed to clients, cost structures, margins per assignment. Consultants, in the vast majority of cases, don't. When a consultant gains the right to ask about average pay levels for their position — and that information must be provided transparently — many conversations that used to be settled in opacity will need to happen in clarity.
The fourth reason is the structural gender bias in IT. Women represent roughly 24% of tech workforce in France. Staffing firms inherit this structurally imbalanced market. But if a pay gap exceeding 5% is found within the firm without objective justification, liability is engaged — regardless of what the rest of the market does. And this bias is rarely conscious or voluntary: it hides in hiring negotiations, promotions, and assignment allocations.
And the fifth reason is the reversed burden of proof, which fundamentally changes the legal position of staffing firms. Today, a consultant who believes they're discriminated against must prove it — which is difficult and discouraging. Tomorrow, it's the firm that must prove it didn't discriminate. Without a documented salary grid, without formalized progression criteria, without traceable compensation decisions, the firm is legally vulnerable to any claim.
Concrete Impacts on the Business Model
Beyond regulatory compliance, it's the business impact that should concern staffing firm leaders. And this impact touches five levers at the heart of profitability.
The first impact is upward pressure on salaries. When transparency becomes effective, consultants will see pay gaps within their own firm. Those paid less will request alignments. Firms will have to correct — meaning increase — which will mechanically compress margins. According to PwC France, over 60% of digital sector companies acknowledge not being ready to apply the directive, meaning the shock will be brutal when it arrives.
The second impact is a complete overhaul of variable pay policies. Verbal bonuses, informal arrangements, bonuses decided "by gut feeling" will need to give way to written, objective, shared rules. This is a 6 to 12-month project for a mid-sized firm — not something you improvise in three weeks.
The third impact is reduced recruitment flexibility. Today, a good BM negotiates hiring salary by instinct, based on the market, timing, and urgency. Tomorrow, the firm must publish a salary range in every posting and stick to it. Less flexibility means less ability to capture top profiles opportunistically — and a need to structure recruitment upstream.
The fourth impact is pressure on daily rates billed to clients. If salaries rise to meet transparency requirements and daily rates don't follow proportionally, margins get crushed mechanically. Firms will either need to negotiate harder with clients to maintain margins, or accept a structural decline in profitability.
And the fifth impact is that attractiveness becomes a structural advantage or handicap. Firms displaying clear, competitive, justifiable salary grids will naturally attract the best talent — those who want to know what they're signing up for. Those that fumble, stay vague, or can't answer a candidate asking "what's your salary policy?" will lose those talents to the former.
The directive won't "add a report." It will reveal all the grey zones in the staffing firm model that have been left untouched for twenty years.The 4 Projects to Launch Now
The good news is that compliance is achievable in 4 to 8 months for a mid-sized firm, provided you start now and don't wait for the final legal text to act. Here are the four priority projects.
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Map Existing Pay Gaps
The starting point is knowing exactly where you stand. Extract payroll data for the last 24 months. Segment by position, seniority level, and gender. Identify all gaps exceeding 5% and verify whether each has a documentable objective justification — rare skill, specific certification, seniority, tight market at time of hiring. If a gap can't be justified, it will need to be corrected. Better to do it proactively, at your own pace, than to be forced after an employee claim.
Formalize Salary Grids and Progression Criteria
This is the most structuring project. Build a grid by position level and seniority, with objective criteria for moving from one level to the next. Variable pay calculation rules must be formalized in writing: BM commissions, mission bonuses, performance bonuses, non-bench premiums. Everything that was verbal or informal must become documented and communicable. And this grid must be communicated internally with transparency.
Update Recruitment Processes
All job postings must systematically include a salary range. All questions about candidates' salary history must be removed from recruitment processes — and BMs and recruiters must be trained on these new obligations. It's a habit change that seems simple but in practice requires support, because "what were you earning before?" is a deeply ingrained reflex in the profession.
Document and Trace Compensation Decisions
Every compensation decision — hiring, raise, exceptional bonus, refused raise — must be documented with its justification. The goal is to be able, in case of a claim, to prove that every decision was made on objective criteria. This requires a tool that centralizes this data in a structured, traceable manner, not scattered emails or handwritten notes in a paper file.
These four projects take approximately 4 to 8 months for a mid-sized firm. Leaders who start in 2026 will be compliant by mid-2027. Those who postpone to 2027 will be exposed legally and commercially.
What Firms That Do This Well Will Gain
It would be reductive to see this directive as purely a constraint. For firms that approach it correctly, salary transparency is a transformation lever that delivers concrete, measurable advantages.
First, a major competitive advantage in recruitment. The best profiles will gravitate toward firms displaying clear, competitive, justifiable grids. In a market where recruiting consultants and BMs is the main growth bottleneck, transparency becomes an employer brand argument as powerful as remote work or benefits.
Second, reduced turnover. Clear, communicated salary rules reduce the sense of injustice, which is one of the top causes of resignation in staffing firms. Each point of avoided turnover represents €30,000 to €80,000 in savings — the gain is direct and measurable.
Third, enhanced attractiveness for female talent. Firms that document a gap below 5%, justified and transparent, will attract more women to a sector that still has too few. It's a CSR lever, but also a business lever: studies consistently show that team diversity correlates with performance.
Fourth, solid legal protection. A firm that has documented its salary policies, progression criteria, and compensation decisions is protected in case of claims. A firm that hasn't is risking its reputation and cash on every potential dispute.
And fifth, higher valuation in case of sale. Investment funds increasingly scrutinize HR maturity and salary governance in their due diligence. A well-structured firm on these topics is worth 15 to 25% more at valuation than one that's behind — a factor that leaders considering a sale within 3-5 years cannot ignore.
Transparency Isn't an HR Problem. It's a Revealer.
The salary transparency directive isn't another report to produce. It's a revealer of a staffing firm's maturity. Those with documented policies, clear grids, and traceable compensation decisions will navigate this transition as an opportunity that differentiates them. Those still managing pay by instinct and case-by-case will face a structural shock — on margins, on recruitment, and potentially legally.
There are 12 to 18 months left to prepare. That's not much. But it's enough if the work starts now.
In this context, centralizing mission-related compensation data — daily rates, margins, BM variables, commissions — in a documented and traceable way becomes a strategic asset. Cobalt doesn't replace a payroll or HRIS tool, but it structures commercial and compensation data on the mission side to facilitate compliance and decision traceability.
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