The EU Pay Transparency Directive for Consulting Firms – What You Need to Know and How to Comply with Cinode

The EU Pay Transparency Directive (2023/970) takes effect in June 2026. Employers with 150 or more employees must submit their first pay report by 7 June 2027, covering pay data from 2026. That means the right data needs to be in place now, not retrofitted later.

Across EU member states, national implementation is still taking shape. Some governments are moving faster than others, and enforcement timelines vary. But the directive is binding, national authorities are gearing up to enforce it, and the overall direction is clear even if exact timelines vary by country.

That is not a reason to wait. It is a reason to act now while there is still time to do it properly.

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Does this only apply to large companies?

No, and that is one of the most common misconceptions. Employers with 150 or more employees face the tightest reporting deadline, but the directive affects all employers regardless of size on several key points.

Pay ranges must be disclosed in job postings. Asking candidates what they currently earn or have earned in the past is no longer permitted. Employees have the right to request written information about their own pay level relative to colleagues in the same job category, broken down by gender. These rights take effect as soon as the law enters into force in each country, not after a transition period.

For companies with 60 to 80 employees, it is worth noting that crossing the 100 or 150 threshold triggers reporting obligations retroactively for that calendar year. Building structure and data quality early is far less costly than retrofitting it under pressure.

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Why are consulting firms particularly exposed?

The directive requires employers to demonstrate pay gaps by gender per job category, meaning groups of employees doing equal work or work of equal value. For consulting firms, this is where things get complicated fast.

Unlike industrial companies with standardised job descriptions, consulting firms typically have wide variation in roles, seniority levels and specialisations. A project manager at an IT consultancy can have a completely different background, skill set and compensation depending on industry focus, certifications and type of engagement. Defining what counts as “equal work” is therefore far from straightforward.

Generic payroll and HR systems rarely capture that context. Cinode has both the pay data and the competence layer needed to make sense of it.

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What is already in Cinode today?

Cinode is uniquely suited for this because the platform already holds exactly the data the directive requires.

💰 Compensation data in the form of base salary and commission. This is the foundation of every gap calculation.

👥 Gender is registered per employee and is the starting point for all comparisons the directive calls for.

🏷️ Job categories can be defined using the existing tag system. Create a tag category called “Job Category”, add tags such as “Senior Developer”, “Project Manager” and “Tech Lead”, assign them to employees and you have defined what counts as equal work in your organisation.

🧠 Competence context through profiles and skills makes it possible to justify objective differences. Employment start date, already stored in Cinode, provides another explanatory variable.

🏢 Teams and organisational structure enable analysis by unit, useful both for internal monitoring and for works council collaboration where required.

You do not need to build a new system. The data is already there.

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From data to insight today, with MCP and Power BI

There is no need to wait for a packaged compliance module. Cinode supports direct data extraction and analysis through two paths that give you a head start.

With Cinode and Claude via MCP, you can already ask direct questions about your Cinode data in plain language. Ask Claude to calculate the median pay gap per job category, identify categories exceeding a five percent gap, summarise gender distribution per pay quartile or flag employees missing a job category tag.

It takes minutes, not months. No coding required.

With Cinode’s Power BI integration you can set up a live compliance dashboard that updates automatically. A working tool that grows with your organisation rather than a one-off export.

For many Cinode customers, a single afternoon is enough to go from zero to first insight. Not a quarter-long IT project.

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Three steps you can take this week

Step 1: Check your data quality. What share of your employees have gender, base salary and job category registered? Aim for 95 percent coverage across all three fields.

Step 2: Create job categories via tags. If you do not already have a tag structure for job groups, start with five to ten categories. Ask yourself: what is “equal work” in your organisation?

Step 3: Run a first analysis. Use MCP with Claude or connect to Power BI and calculate the gap per category. A manual Excel export works too. Which categories sit below five percent? Which ones need an explanation?

Pay transparency is not a one-time project. It is an ongoing process that needs to be part of your HR calendar alongside salary reviews and performance conversations. Cinode is built to be the operational hub of a consulting firm. Pay transparency is a natural next step in that work.

Want to know more about setting up your pay analysis in Cinode today? Get in touch and we will help you get started.