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HR and internal pay rules: how to prepare processes, policies, and communication

HR, internal rules, and workers' rights under Directive (EU) 2023/970

The issue of pay transparency is not only about salaries, but also about processes, rules, and rights. This article shows how HR can prepare internal documents, recruitment, and communication with workers in a logical and sustainable way.

Why HR is at the center of the change

Directive (EU) 2023/970 affects remuneration, but its real implementation goes through HR processes. HR teams prepare job roles, coordinate recruitment, manage annual reviews, maintain internal rules, and often answer questions about pay transparency. That is why their role is crucial.

If processes are scattered, no policy will work well. If they are organized, the organization can introduce clear practices that reduce risk and increase trust.

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What HR should review first

The first task is to review the internal rules for remuneration, recruitment, promotion, bonuses, and performance reviews. It is a good idea to compare the documents with actual practice, because the gap between what is written and what is done is one of the biggest risks. If the rule exists only formally, it will not help when questions about equal pay arise.

Next, you should check how decisions are documented. For example, if a higher starting salary is offered, is there a recorded reason to justify it? Are there criteria for bonuses? Is there consistency in promotions?

Pay transparency in the recruitment process

Recruitment is one of the first places where the new expectations will be strongly felt. Candidates increasingly want information about salary ranges, selection criteria, and opportunities for development. For employers, this means formulating offers more clearly and not relying on vague, non-committal wording.

In practice, it is useful for the recruitment process to have predefined salary ranges rather than determining salary ad hoc after several rounds of negotiation. This supports both consistency and the defensibility of decisions.

How to prepare the internal rules

Internal remuneration rules should reflect the company’s actual logic. It is useful to describe salary levels, the main positioning criteria, the conditions for increases, and the principles for bonuses. The document does not need to be overly detailed, but it should be clear enough to be applied consistently.

A good practice is to include rules for exceptions as well: who approves them, in what cases they are allowed, and how they are documented. This is important because exceptions are often what lead to unexplained differences.

What is the role of managers

Managers directly influence many pay decisions, even when they do not sign the formal documents. They recommend promotions, assess performance, and discuss market expectations. If they do not have a common framework, the risk of inconsistency is high.

HR should prepare managers with clear guidance: how to propose salary, how to explain differences, how to talk about bonuses, and what to say when an employee asks about work of equal value or equal pay.

What this means for workers' rights

Greater transparency usually leads to a clearer awareness of rights. Workers and employees will expect better visibility into pay criteria, promotion conditions, and how similar roles are compared. This does not mean unconditional access to all data, but it does mean clearer and more respectful communication.

HR should prepare standardized answers and internal guidance so it can respond consistently to such questions without improvisation.

Communication with workers and employees

Communication should not begin only when there is tension. It is better to explain the change in advance: why it is being made, what is being aimed for, what will change, and what will not change. Employees usually accept new rules more easily when they see that they bring consistency and predictability, not just control.

It is also useful to explain what work of equal value means in the specific context of the company. This shifts the conversation from abstract claims to real criteria and roles.

How to organize the annual cycle

For transparency in pay to have a lasting effect, it must become part of the annual HR cycle. This means regular review of the remuneration structure, analysis of differences, assessment of variable pay, and review of internal rules. If these steps are taken only in a crisis, the organization loses the advantage of prevention.

It is a good idea for the annual plan to include specific deadlines and responsibilities — who collects the data, who analyzes it, who makes the decisions, and who communicates the results.

Practical example

In a company with a growing team, HR finds that different managers conduct salary discussions in different ways. One offers a specific range, another starts from the candidate’s last salary, and a third decides based on intuition. After introducing a common offer framework and short training for managers, the differences decrease significantly. This does not eliminate individual cases, but it makes the system more sustainable and easier to explain.

What to include in the HR plan

  • review of all remuneration policies;
  • update of job descriptions;
  • clear rules for starting offers and ranges;
  • procedure for bonuses and promotions;
  • training for managers;
  • communication plan for employees;
  • periodic compliance review.

How HR should work with the legal and finance teams

Since the topic combines remuneration, data, and labor law, the best model is joint work between HR, finance, payroll, and the legal team. HR usually brings the main information about processes, payroll — about the data, finance — about the budget, and lawyers — about the legal framework. Only together can they prepare a functioning system.

This is especially important when handling sensitive topics such as pay differences between women and men or when assessing equal pay for different but comparable roles.

What to do right now

Review the internal rules and select three areas for immediate update: recruitment, bonuses, and promotions. Prepare short guidance for managers and standardize answers to frequently asked questions. If you are looking for a broader framework, see also the main guide and the material on Pay transparency: how to build a clear salary structure.

Conclusion

HR is where pay transparency turns from principle into practice. When internal rules are clear, managers are prepared, and communication is consistent, the organization can much more easily meet the expectations of Directive (EU) 2023/970 and build a fairer remuneration system.

Sign up for our Webinar How to prepare your business for Directive (EU) 2023/970:  Pay transparency and equal pay

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