Equal Pay Directive: What should HR and management in Norway do now?

The EU's Pay Transparency Directive does not yet apply in Norway , and there is no set Norwegian entry into force date. Nevertheless, the directive clearly points the way for future requirements for pay, transparency and documentation. For Norwegian employers, this means that pay is increasingly becoming a strategic management responsibility : less room for individual explanations, more need for structure, consistency and clear pay criteria. Businesses that start preparations now will be in a much stronger position when the regulations one day become part of Norwegian law.

The Equal Pay Directive is an EU regulation that aims to ensure equal pay for women and men through increased pay transparency. The directive was adopted in 2023 and requires employers to provide transparency on pay levels, pay criteria and pay gaps to employees, job seekers and the public.

Daniel Edenholm, founder of Sysarb, explains it this way:

The directive must be implemented in national legislation in the EU by 7 June 2026. For Norway, the regulations must first be incorporated into the EEA Agreement and then implemented into Norwegian law. Many countries are now pointing to 2027 as a realistic entry into force.

Therefore, new requirements for Norway may come quickly when the directive is first incorporated, and many businesses want to be at the forefront.

"Norway will probably follow suit once Sweden and the EU have settled on their solutions," says Edenholm.

In practice, this means that employers must move from individual and informal salary assessments to structured, documented and verifiable salary models. Salary can no longer be explained from person to person – it must be explained systematically.

The most important requirements:

• Common job architecture ( job assessment of roles)
• Clear salary ranges per level
• Clear salary criteria for individual salary
• Annual wage gap reporting (for larger businesses)

“Without a common structure, it becomes impossible to explain or defend wage differences,” says Edenholm.

For Norwegian businesses, this means that the groundwork must be in place long before any new requirements come into effect . Those who already work well with ARP have a clear advantage – but many will have to professionalize both their salary structure, documentation and management communication to meet what is likely to come.

Job seekers will have the right to know the salary range for the position before salary negotiations begin. Employers can no longer ask candidates about previous salaries.

"In practice, this means that the employer makes the first offer in salary negotiations," explains Edenholm.
"It reduces the risk of historical wage gaps being perpetuated."

If the Equal Pay Directive is implemented in Norwegian law, employees will have expanded rights to access how pay is determined. This includes the right to information about the pay model, pay criteria and statistics showing average pay for women and men in the same or equivalent roles. Employers will have to respond to such requests within two months.

For Norwegian employers, this will mean a clear shift: Salary can no longer be an individual and poorly documented matter, but must be part of a clear, structured and verifiable model.

Important to note – if the regulations are introduced in Norway:

• Employees cannot be sanctioned for requesting salary transparency
• Clauses prohibiting employees from discussing salary will be invalid
• The employer must be able to explain wage differences using objective and gender-neutral criteria.

“It is forbidden in the EU to keep salaries secret,” says Edenholm. “This is a big change for many employers.”

Although these rights do not apply in Norway today , they clearly point the way for future requirements . Norwegian businesses that are already working systematically with pay structure, documentation and transparency will be far better equipped when – and if – the regulations become part of Norwegian law.

Daniel Edenholm refers to research on perceived justice:

"The experience of injustice has a far greater effect on motivation than both salary level and salary increase."

The two most important factors for perceived fairness are:

1. A transparent and consistent salary model
2. Good dialogue between manager and employee

"Good communication with your manager means more than a high salary."

To be prepared for the Equal Pay Directive, businesses should already establish job architecture, define salary ranges, and ensure that salary criteria are understandable and verifiable.

Recommended starting point:

• Build or update job architecture
• Establish a salary range that can be communicated
• Describe how individual salary is determined
• Clarify the desired level of salary transparency
• Prepare managers to explain salary – not just set it

“This is not an HR project alone,” concludes Edenholm.
“It is a leadership responsibility.”