Pay transparency: only one in three companies is at an advanced stage

Three months after Legislative Decree 96/2026 came into force on 7 June – a decree which transposed the European directive on pay transparency into Italian law – only one in three companies is at an operational or advanced stage in implementing the required obligations and compliance measures. 90.3 per cent are aware of the timetable and requirements of the new legislation, and 60.4 per cent report that the level of preparedness amongst human resources managers has increased. These are some of the findings of a survey conducted in September by the Italian Association for Personnel Management (carried out by the Aidp research centre headed by Umberto Frigelli), which Monday’s edition of *Il Sole 24 Ore* is able to reveal in advance. The survey received responses from human resources directors at 434 companies, ranging from small to medium-sized and large enterprises.

European Directive 2023/970 aims to strengthen the enforcement of equal pay for men and women for the same work or for work ‘of equal value’, through pay transparency. In the EU, the average pay gap between women and men is 11 per cent, but there are significant differences between countries and also between the public and private sectors. In Italia, the gender pay gap in hourly pay in the private sector stands at 17.4 per cent, but rises to 23.4 per cent in professional, scientific and technical occupations, and to 21.8 per cent in the finance sector.Among the obligations under Legislative Decree 96/2026, which is already in force for companies, is the requirement to publish the starting salary or the salary band to be assigned to each position during the recruitment process. Furthermore, from 7 June, employees may ask their employer for the average pay levels, broken down by gender, for categories of staff performing the same work or work of equal value.There is also a series of reporting obligations regarding pay levels, which come into effect from 7 June 2027, with different start dates depending on the size of the company. There will also be an obligation to carry out a joint pay assessment with the trade unions if the pay gap between female and male workers exceeds 5 per cent, and this difference has not been explained by the employer or rectified within six months.Identifying which categories of workers perform the same or comparable duties and mapping pay gaps is a task that requires companies to put in place a dedicated organisational structure.

The Aidp survey reveals that, taking all responding companies into account, 19 per cent have already begun implementing the new requirements, 6 per cent are at an advanced stage of implementation, and 9 per cent already have a defined plan. In effect, therefore, one in three companies is well on the way.However, the level of maturity varies considerably depending on company size. When companies are grouped into three categories, it emerges that the proportion of those at an advanced stage rises from 22.2 per cent for those with fewer than 250 employees, to 32.8 per cent for those with between 250 and 999 employees, reaching 56.8 per cent in organisations with at least 1,000 employees. Branches of foreign multinationals show the highest proportion of advanced/operational implementation, at 42.2 per cent, followed by Italian multinationals (35.8 per cent), whilst family-run businesses stand at 23.7 per cent.

“We have moved,” explains Roberto Mattio, national vice-president of Aidp and head of human resources at the Pininfarina Group, “from an initial phase of familiarising ourselves with the new pay transparency regulations to a phase of implementation. Companies are getting organised, although only a third are at a more advanced stage. To define work of equal value, it is necessary, for example, to have grading systems in place within the company. The survey we conducted reveals that one of the main challenges, for almost half of the companies interviewed, is determining objective, non-discriminatory and neutral criteria on which to base remuneration systems.”

Looking at the measures actually undertaken, 41.7 per cent of companies are providing HR and management training, whilst 35.9 per cent are updating their HR policies and procedures. One in four companies, however, states that it is still finalising the measures to be implemented. The majority of the investment made – accounting for 56 per cent of companies – is in hours of internal HR staff dedicated to pay transparency, and 38.7 per cent is in specialist external consultancy.Trade union involvement in implementing the directive still appears limited: 77.3 per cent of companies have not yet involved them or do not plan to do so. But what impact has the new legislation had on reducing the gender pay gap? Only 52 per cent of the companies surveyed by AIDP have concrete data: in 35.7 per cent of cases, the gap remains essentially unchanged; in 15.2 per cent, it is narrowing; and in 1.2 per cent, it is actually widening. It therefore appears that the ability to measure the phenomenon is developing faster than the ability to change the situation. Over half of the companies, however, state that they have a positive attitude towards the requirements relating to pay transparency: for 50.9 per cent, ‘it is an opportunity to improve fairness in the workplace’.