The government has stopped hinting and committed. It has announced plans to make it a legal requirement for employers to publish salary information in job adverts, which it is calling a “say what you pay” law. The announcement follows the Cabinet Office consultation on equal pay and pay discrimination, which ran from 14 July to 27 October 2026. Alongside proposals on pay transparency, the consultation covered effective equal pay rights for ethnic minority and disabled workers, a new equal pay enforcement unit, and measures to stop outsourcing from being used to avoid equal pay obligations. Legislation is promised “as soon as possible,” but no implementation date has been announced. The prime minister has, however, urged employers to start now.
Key details remain open, including whether employers must state a specific salary or may give a range (and, if so, how wide it can be), whether only basic salary must be disclosed or other remuneration such as bonuses too, and what happens where there is no advert.
Following the EU’s Lead
The UK’s approach closely tracks the EU Pay Transparency Directive, which member states were required to transpose by 7 June 2026 and which requires employers to disclose starting pay or a pay range in the advert or before the interview. Under the Windsor Framework, the post-Brexit arrangements governing aspects of Northern Ireland’s relationship with the EU, Northern Ireland may also need to keep pace with the Directive, raising the prospect of different regimes within the UK.
Will more countries follow? Momentum suggests yes. With the EU’s 27 member states now under a common standard and the UK legislating, pay transparency is becoming the expected baseline, and multinationals may simply adopt one global approach. The open question is whether the UK will go beyond job adverts to match the Directive’s wider measures.
The Practical Difficulties
Acas, the independent public body that provides advice and guidance on workplace rights and employment relations in the UK, supports the change but has warned that any requirement must be “sufficiently specific to prevent unintended consequences or exploitable loopholes.” It noted that disclosing base salary alone may hide large differences in bonuses, allowances, and other benefits. Issues include:
- Very wide bands. A range of “£30,000 to £70,000” complies on paper but tells candidates little unless the rules limit how wide bands can be.
- Recruitment agencies. Agency adverts often omit the employer’s name. Would an advert that does not name the employer still be compliant?
- Unadvertised and variable pay roles. Headhunted and internal appointments may never be advertised, and base salary may say little where bonuses or commission are significant.
- Before publishing pay with confidence, employers will need to carry out job evaluation and have a clear pay and reward structure. Many smaller employers, which set pay case by case, do not have this.
- Existing staff. Advertised pay may reveal that current employees are paid less, prompting grievances or equal pay claims.
What Employers Should Do Now
With the detail still to come, wholesale changes to hiring practices can wait. Groups with international workforces may find they are already well on the way, given how far pay transparency rules have moved in Europe, several US states, and beyond. In the meantime, employers should:
- Audit live vacancies, both in-house and through agencies, to see how many already show pay.
- Consider the pay bands for each role and whether they are appropriate and justifiable.
- Carry out an internal comparison between proposed pay for new recruits and the pay of employees in comparable roles, identifying any disparities and the reasons for them. Where appropriate, this exercise could be undertaken with legal input on a privileged basis.
For further information or assistance with the above, please contact a member of our international labor and employment team.
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