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Pay Transparency: Where Does France Really Stand This Summer of 2026?  

The Essentials

France has not transposed Directive 2023/970 by the June 7, 2026, deadline: only 4 of the 27 Member States have done so to date (Italy, Slovakia, Malta, and Lithuania). The directive is now expected to take effect under French law on January 1, 2028. This delay does not eliminate existing obligations: the professional equality index remains mandatory for companies with more than 50 employees. According to Robert Walters and Figures, more than one in two companies does not feel ready, while 47% of employees plan to demand transparency as soon as the directive takes effect.

June 7, 2026, has come and gone. That was the deadline set by the European Union for each member state to transpose Directive 2023/970 on pay transparency into its national law. While France did not meet the deadline, it is far from being the only country in this situation (only Italy, Slovakia, Malta, and Lithuania have fully transposed the directive to date). However, this delay raises a real question for HR and C&B departments: should they wait for the final text before taking action, or should they start preparing now?

 

A legislative schedule that has fallen behind schedule

The transposition bill has had a tumultuous journey. Consultations with the social partners began in May 2025, were suspended following the change in government in the fall, and then resumed in early 2026 at the initiative of the new Minister of Labor. A new version of the bill was submitted to the Council of State in early June 2026, but no date has yet been set for its review by the Council of Ministers or for its consideration by Parliament. The current goal is to hold a vote by the end of the year, before the 2027 presidential election, with the law potentially taking effect on January 1, 2028.

Two points of contention partly explain this delay, beyond the political and institutional context: the threshold for application (employers are advocating for limiting it to companies with 100 employees, as provided for in the Directive, while labor unions are pushing to extend it to companies with 50 or more employees) and the level of penalties provided for.

 

What remains the same: Your current obligations remain in effect

The delay in transposition does not create a legal vacuum. Companies with more than 50 employees must continue to publish their professional equality index in accordance with current rules; there will be no “blank year” in 2026. This index, which has shown steady improvement since its inception, will eventually be replaced by seven separate indicators modeled after the requirements of the European directive; however, this overhaul will not take effect until the French law comes into force.

 

What the directive will change, in practical terms

Once transposed, the directive will require, among other things:

  • More transparent salary information starting at the hiring stage: job postings must specify a starting salary or a salary range based on objective criteria, and employers will no longer be allowed to ask candidates about their previous compensation.
  • Expanded right to information for employees, who will be able to request data on average pay levels broken down by gender for employees in their category (work of equal value), without, however, receiving personally identifiable information about their colleagues.
  • A reversal of the burden of proof in the event of a dispute: it will be up to the employer to demonstrate the absence of wage discrimination, rather than the employee having to prove it.
  • Financial penalties proportional to total payroll, full compensation for employees who have been discriminated against, a doubling of certain criminal penalties for repeat offenses, and restrictions on access to public procurement for non-compliant companies.
  • Implementation must take place within one year of the law’s enactment, with a phased rollout for the 7th indicator by category, based on company size: within 3 years for companies with 100 to 149 employees, and within 6 years for those with 50 to 99 employees.

 

Why plan ahead now?

Recent surveys by Robert Walters and Figures indicate that more than one in two companies do not feel ready to implement the directive’s new provisions. At the same time, 47% of employees plan to demand pay transparency as soon as the reform takes effect. The postponement of the French timeline therefore provides valuable time, though it is limited given the scope of the task: auditing existing pay scales, establishing job categories, identifying unjustified pay gaps between positions of comparable value, overhauling or adapting recruitment processes, training managers in pay communication, and so on.

 

At MCR Group, we’ve observed firsthand that companies that have already embarked on this process are reaping a threefold benefit: a more stress-free path to compliance, a genuine ability to plan now for budgets to address discrepancies—which can be spread out over time—and a real boost to employer trust and appeal.

 

And ultimately, a compensation policy that can be explained and justified is also one that ensures fairness and fosters commitment and recognition!

 

If compensation is a topic that interests you, we invite you to check out our selection of white papers...

Frequently Asked Questions

Why hasn't France implemented the Pay Transparency Directive by the deadline?

The bill has had a tumultuous journey: consultations began in May 2025, were interrupted by a change in government in the fall, and resumed in early 2026. A new version of the bill was submitted to the Council of State in early June 2026, but no date has yet been set for its parliamentary review. Two points of contention remain: the threshold for application (100 employees according to the directive, but unions are pushing for 50 employees) and the level of penalties provided for.

Does the delay in transposition create a legal vacuum for French companies?

No. The current requirements remain fully in effect: companies with more than 50 employees must continue to publish their gender equality index in accordance with existing rules. There will be no “blank year” in 2026. This index will eventually be replaced by seven separate indicators modeled on the requirements of the European directive, but this overhaul will not take place until the French law goes into effect.

What, specifically, will the new obligations imposed by the directive be once it has been transposed?

There are four major requirements to anticipate: the requirement to specify a salary or salary range in job postings; the prohibition on asking a candidate about their prior compensation; the right of employees to access average compensation figures broken down by gender within their job category; and the reversal of the burden of proof in the event of a dispute (the employer will be required to demonstrate the absence of discrimination, rather than the employee). Financial penalties proportional to the total payroll and restrictions on access to public procurement contracts will round out the framework.

Which companies will be affected, and what is the timeline for compliance?

Implementation will take place within one year of the French law’s enactment, with a phased timeline based on company size: within three years for companies with 100 to 149 employees, and within six years for those with 50 to 99 employees. The political debate continues to focus on the minimum threshold for application: the directive sets the threshold at 100 employees, but labor unions are advocating for lowering it to 50 employees in the French implementation.

Why is it in companies' best interest to start planning now, despite the delay in transposition?

According to surveys by Robert Walters and Figures, more than one in two companies do not feel prepared, while 47% of employees plan to demand transparency as soon as the law takes effect. The scale of the task justifies taking action now: auditing pay scales, establishing job categories, identifying unjustified pay gaps, overhauling recruitment processes, and training managers. Spreading these adjustments out over time is far less costly than having to implement them urgently once the law is enacted.

What concrete benefits are forward-thinking companies reaping today?

Companies that have already begun this process are seeing three key benefits: a smoother transition to compliance once the law takes effect; the ability to plan ahead and spread out the costs of addressing pay gaps over time; and a genuine boost to internal trust and employer brand appeal. A compensation policy that can be clearly explained and justified is also one that ensures fairness and fosters employee engagement. MCR Groupe supports companies in this proactive approach.

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Article written by:
The MCR team