Acting proactively
The pay transparency requirement is here. Even though the EU Pay Transparency Directive has not yet been fully transposed into German law, the underlying principle already applies in practice: the right to information and the obligation to explain pay differences.
This is not a “nice-to-have,” but a fundamental value: equality before the law—and with it, the right to equal pay for equal work or work of equal value. That idea is now becoming part of day-to-day business.
What matters less is the exact legal wording, and far more how well companies explain, frame, and stand behind pay transparency in everyday conversations.
Where companies really stand today
As long as it remains unclear what the final German legislation will look like, many companies are communicating very cautiously with their employees. Our conversations with clients paint a similar picture: only a few DAX companies are already pursuing active, open communication. The reasons are understandable:
- Pay transparency can feel like a bureaucratic burden.
- There is uncertainty about whether criteria such as responsibility, workload, skills, and working conditions are truly robust and explainable.
- There is concern about complaints, lawsuits, and reputational damage.
These questions are legitimate. They become problematic when they lead to paralysis. A better alternative is to build trust—through solid preparation and clear communication.
You need a pay philosophy—and people who can tell the story
You don’t need a 100-page playbook to get started. But you do need a clear, robust pay philosophy—a narrative. It should answer, among other things:
- What does your company pay for—and what does it not?
- How do you weigh responsibility, workload, skills, and working conditions?
- Which pay structures and ranges exist—and why?
- How does your pay compare to the external market?
- How large is your gender pay gap?
On this basis, you can explain pay differences in a factual and consistent way. But paper alone does not build trust.
A pay philosophy only becomes effective when people inside the company can explain it clearly, put it into context, and stand behind it in dialogue—your messengers.
Pay transparency is also a communication task. And communication needs faces that people will listen to—and believe. Neither the executive board nor HR business partners are automatically the best communicators for this topic. The expertise usually sits in HR and Legal, so Internal Communications should be involved early.
At the same time, you need integrators who can translate this expertise, put it into context, and connect it to your company values. These people—or this team—are your pay transparency messengers. Their role is to:
- explain your pay logic in simple, accessible language,
- address questions before they turn into rumors,
- acknowledge critical issues honestly,
- actively shape the dialogue with employees.
Choosing the right messengers is just as critical for success as getting the content right.
What makes a strong messenger
Here we are deliberately not talking about “target groups,” but about the people who send the messages. It’s worth taking a close look at who they are. Helpful questions include:
- Who is credible—regardless of hierarchy level?
- Who visibly stands for your company values and embodies fairness, openness, and respect?
- Who can explain complex content in a clear, human way—without legal jargon?
- Who can stay open and dialog-oriented, even when questions get tough?
Messengers are not just spokespeople. They build bridges—between pay logic, business strategy, and employees’ real-life experience. Typical profiles might include:
- a credible CPO or CHRO who is visibly committed to equal pay,
- total rewards experts who can explain data and systems,
- selected leaders who are seen as fair and approachable,
- HR business partners with a strong connection to the business—if they are well prepared,
- specially trained employees who act as corporate influencers.
What matters is not the job title, but the combination of expertise, credibility, and communication skills.
CEO, CPO, or HRBP? The right roles for the right messages
Around pay transparency, you need a well-orchestrated mix of messengers—with clearly defined roles:
- CEO: Sets a visible commitment from the top. Message: “Pay transparency is a leadership priority and part of our culture.”
- CPO/CHRO: Represents the strategic HR perspective and the values behind it. Message: “This is how we define fairness—and how we shape equal pay over the long term.”
- Total Rewards-Experts: Provide the technical depth. Message: “This is how our system works—and this is how differences are explained.”
- HR Business Partner:
- People managers: Build trust in the line organization. Message: “This is how we answer your specific questions.”
- Recruiters: Already represent your pay transparency externally today. Message: “This is how we, as an employer, handle pay transparency.”
Whoever speaks must be prepared, aligned, and confident in their role. Spontaneous communication on pay transparency tends to create risk, not clarity. Done well, pay transparency can become a real differentiator for your employer brand.
How to equip your messengers
Strong messengers don’t appear out of nowhere. They are selected deliberately, enabled, and supported continuously. Important building blocks include:
- Clear role profiles: Who owns which messages—and which not?
- A shared storyline: Which core messages apply across the company?
- Argumentation guides and Q&A: Which critical questions should you expect—and how do you answer them?
- Training and sparring: How do messengers deal with emotions, criticism, and uncertainty?
- Clear escalation paths: What happens when a question cannot be answered on the spot?
The better your communicators are equipped, the more confidently they can show up—and the more trust you build.
Non-communication is also a message
Pay transparency is a fundamental decision. It cannot be handled “on the side.” Companies that choose not to communicate are still sending a very clear message:
- Non-communication creates room for interpretation.
- Room for interpretation creates mistrust.
- Mistrust reduces motivation and engagement.
Organizations that fear lawsuits today have usually sown mistrust long before. The new regulation does not create this problem—it makes it visible and forces a response.
The costs of doing nothing are high: financially, and in terms of your employer reputation.
Once trust is lost, rebuilding it takes time.
How we support companies
Our communication solutions for pay transparency start exactly where the real challenge lies—with communication. We connect solid pay logic with clear, credible messaging. We support companies in:
- identifying suitable messengers in the organization,
- defining roles and responsibilities,
- developing consistent key messages and argumentation guides,
- enabling messengers through training, sparring, and tailored materials.
In parallel, we work closely with total rewards experts and translate existing pay philosophies into communication that fits both the company and its communicators.
For organizations, this means that leaders and HR teams gain confidence in conversations about pay transparency. Misunderstandings and escalations become less frequent because employees understand how pay works in the company, why it is fair, and where improvements are being made where needed.
A quick messenger check for pay transparency
Three questions for a fast reality check:
- Who is visibly talking about pay in your company today—and how well prepared is that function?
- Is there a shared, aligned storyline (the narrative) that all communicators can refer to?
- Do your CEO, CPO/CHRO, HRBPs, and leaders know exactly which role they play in pay communication—and where their limits are?
If you hesitate on any of these questions, this is a good time to sharpen your messenger strategy.
In a compact sparring format, we work with you to analyze your current setup and define concrete next steps to make your communicators strong ambassadors for pay transparency.
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CONTACT US
If you’d like to chat about this, or any other topic, get in touch with us.
We lead People-Projects to success through communication.
Your contact person
- simone[@]unequity.com
- +49 (0) 174 / 310 78 27
- Simone Schmitt-Schillig
Sources:
Entgelttransparenzgesetz of the Federal Republic of Germany
EUPTD European Pay Transparency Directive
Gender Pay Gap, refer to Download
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