Key Strategic Employment Issues to Consider for 2022 - #6

Proposed EU Directive on Pay Transparency


On the 4th of March 2021, the European Commission issued its proposal for a Directive on pay transparency. The objectives of the proposal is aligned to those of the European Pillar of Social Rights. Equal opportunities, equal pay between men and women and pay transparency are key elements of modern, dynamic and inclusive labour markets. However, employer bodies are concerned about aspects of the proposal including the scope of the directive, i.e., by ensuring that its application to companies is limited to above a certain size with this limit being decided at national level. A range of issues have been pressed by different member states, including:


  • The level of detail of the proposal and possible conflict with principle of proportionality.

  • Conflicts with national competences on certain issues and possibly with the principle of subsidiarity (in particular the role of social partners and social dialogue in setting and enforcing wages).

  • Lack of legal certainty.

  • Practical, financial and administrative impact of the proposal, especially on SMEs.

  • Member states have also asked for clarifications regarding the provisions of the directive and the link to the right to equal pay.


The EU Employment Council meeting of 6th December reached a provisional agreement on the Directive (general approach). The European Parliament is currently still working on its position on the Commission proposal for the Directive.


If you would like to talk to us about any of these issues, or about engaging your people through the period ahead, please get in touch with me at brendan.mcginty@stratis.ie or any one of our Partners.

Brendan McGinty

Managing Partner

Stratis Consulting

‘Strategic Employment Relations’

E: brendan.mcginty@stratis.ie

T: +353 (0) 1 2166302

M: +353 (0) 87 2433038

W: www.stratis.ie Twitter: @Stratisconsult LinkedIn: Follow us here


Disclaimer: The information in this article is for practical guidance only and does not constitute legal or case specific advice. The answers to specific situations will vary depending on the circumstances of each case. This is not a substitute for specific professional advice relevant to individual circumstances facing your business.

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