Case Study: Preparing for the EU Pay Transparency Directive

Pay Transparency Diagnostic and Reward Strategy Roadmap for a Global Airline

Type of Activity

A two month EU Pay Transparency Directive Diagnostic to assess organisational readiness and develop a practical roadmap for compliance. Alongside this, Gemma provided broader consultancy to shape a Total Reward Strategy aligned with ongoing business transformation and workforce engagement goals.

Preparing a Global Airline for the EU Pay Transparency Directive

The organisation is a major international airline headquartered in Western Europe, employing several thousand people across multiple countries. Operating within a highly regulated, unionised and competitive sector, the business is undergoing a period of strategic transformation focused on operational excellence, employee engagement, and sustainable growth.

With a complex workforce structure and diverse employment models, the company faces the dual challenge of maintaining compliance with emerging regulations, including the EU Pay Transparency Directive, while ensuring its reward frameworks remain fair, competitive, and aligned with business strategy. This context made it an ideal environment to strengthen both pay transparency readiness and the organisation’s broader Total Reward Strategy.

The Challenge

With the EU Pay Transparency Directive nearing implementation, this leading European organisation sought to strengthen its accuracy and readiness around pay transparency, reporting and compliance.

While initial planning had begun internally, the HR and Reward teams sought expert input to:

• Assess their current state of readiness against the directive’s requirements
• Clarify what the legislation meant in the context of their structure and workforce
• Develop a clear roadmap toward pay transparency compliance and sustainable pay equity
• Align reward strategy, communication and governance with its broader people strategy and organisational transformation programme.

The project also created a valuable opportunity to strengthen reward positioning, ensuring fairness, transparency, and alignment between pay structures and business objectives.

The Approach

Gemma delivered a tailored EU Pay Transparency readiness diagnostic, combining regulatory insight with practical, strategic application.

Her approach translated complex legal, pay reporting and reward design issues into actionable steps that the internal team could own and sustain. 

Key activities included:

• Conducting a Pay Transparency Diagnostic Review aligned with EU Directive requirements
• Talking to key Executive stakeholders, including the Group CEO and Group CFO
• Developing a detailed Pay Transparency Roadmap outlining immediate actions and longer term strategic priorities
• Facilitating an engaging workshop for HR & Reward Leadership stakeholders to build awareness, clarity and accountability
• Advising on the broader Total Reward Strategy, ensuring alignment between pay transparency, business transformation and workforce engagement.

Through this process, Gemma helped the team understand the implications of the EU Pay Transparency Directive not only as a compliance requirement, but as a catalyst for more transparent, equitable and motivating reward practices.

The Outcome

The organisation now has a clear, actionable plan in place; a practical roadmap that guides both compliance with the EU Pay Transparency Directive and broader reward strategy development.

The work created a strong foundation for long term progress by:

• Establishing a structured, step-by-step plan to achieve EU pay transparency compliance ahead of 2026 deadlines
• Clarifying roles, responsibilities and governance for ongoing pay reporting and communication
• Aligning pay and reward frameworks with the organisation’s evolving business and culture goals
• Equipping internal HR and Reward teams with the tools, capability and confidence to lead future implementation independently

Gemma’s approach brought deep expertise, clarity and flexibility, enabling the organisation to move from uncertainty to structured readiness. Internal feedback highlighted how the process not only enhanced understanding of the directive but also elevated reward thinking across the business; connecting compliance with culture, engagement and strategic transformation.