Sometimes it feels as if Brussels is setting the agenda – and Luxembourg is still on the sidelines. That’s exactly the case with the new Pay Transparency Directive: the EU has already passed the rules, but Luxembourg has not yet put them into national law. The deadline, June 2026, is closer than many HR teams might like to admit.
So what does this mean for HR today? Even without a local law, the direction is clear:
- Job ads will need to state pay ranges, and questions about salary history will be off the table.
- Employees will gain the right to request pay information compared to colleagues in equal-value roles.
- Companies of a certain size will be required to publish structured pay reports – for some, this will be entirely new territory.
The real challenge is not the legislation itself, but the practical preparation. Many companies in Luxembourg – whether in banking, industry, or the start-up scene – don’t yet have payroll data structured in a way that allows meaningful gender-based analysis.
Advisors are giving a consistent piece of advice: start now. Clean up the data, run internal pay-gap simulations, and adjust recruitment processes ahead of time. Waiting until the national law is finally written risks leaving HR departments under severe time pressure – with high compliance and reputational risks if gaps remain unexplained.
