From the job interview to the monthly payslip, pre-employment disclosure obligations and salary confidentiality are concepts that will undergo significant changes under Directive (EU) 2023/970.
The Directive expands employers’ obligations during the recruitment process: candidates must be informed of the initial salary or salary range applicable to the position, either in the job advertisement or through direct communication, in both cases before the job interview takes place, enabling them to participate in the selection process on an informed basis.
The Directive also changes the regime governing salary confidentiality clauses, limiting their scope so that they can no longer be relied upon to discourage employees from verifying or exercising their right to equal pay. What exactly is changing, to what extent do existing confidentiality clauses remain valid and how should employers review and update them?
As the Directive entered into force on 7 June 2026 and Romanian implementing legislation is expected shortly, pay transparency is no longer simply a topic to monitor from a distance—it is a change for which employers should start preparing now.
During the workshop organised in June by Voicu & Asociații, we discussed, based on the latest version of the draft legislation, the practical implications of Directive (EU) 2023/970, including objective remuneration criteria, enhanced information rights for employees and new reporting requirements concerning pay differences.
For companies, the next step is clear: start preparing for compliance early. Reviewing remuneration policies, HR processes and internal evaluation criteria can become a significant advantage, leading to greater predictability, more robust remuneration decisions and internal mechanisms that can withstand review by regulatory authorities and courts.
At Voicu & Asociatii, we have already developed expertise in assisting organisations with compliance under Directive (EU) 2023/970 and can support you in assessing its impact on your remuneration framework, as well as in designing a compliance roadmap tailored to the specific needs of your organisation.
