Applicants must receive starting pay information early enough for an informed and transparent negotiation about pay. Article 5 of Directive (EU) 2023/970 lists a published job vacancy notice, disclosure before the job interview or another suitable method as examples. The European Commission now summarises the practical rule as disclosure in the vacancy notice or ahead of the interview. Employers should therefore define a clear pre-interview disclosure point unless the applicable Member State requires salary information even earlier, such as directly in the vacancy notice.
Jurisdiction: European Union
The Governing Standard Is Informed and Transparent Pay Negotiation
Article 5 does not frame the timing rule as a simple number of days before an interview. It says the information must be provided in a way that ensures informed and transparent negotiation on pay. That purpose is important when employers design the recruitment process. The candidate should know the initial pay or range early enough to understand the financial basis of the role before investing heavily in the process or negotiating compensation. A technical disclosure that arrives only after the key decisions have already been made would not serve the same function.
Article 5 Gives Vacancy Notice and Pre-Interview Disclosure as Examples
The Directive identifies a published job vacancy notice and disclosure before the job interview as examples of how the employer can provide the information. It also leaves room for another method that achieves the same objective. This flexibility allows different recruitment systems to comply without forcing every employer into one communication channel. The employer still needs a clear internal rule. If the salary is not published in the vacancy, the process should make sure the applicant receives it before the interview stage in line with the Commission's current practical explanation and any national requirements.
The Commission Says Vacancy Notice or Ahead of the Interview
The European Commission's June 2026 explanation states that employers will have to inform job seekers about the starting salary or pay range in the vacancy notice or ahead of the interview. For compliance teams, this is a useful operational formulation because it removes the temptation to delay disclosure until an offer is being prepared. An employer can choose the vacancy as the standard disclosure point across the organisation or, where permitted, use a documented pre-interview communication. Either way, the applicant should receive the information before interview-stage pay discussions occur.
Disclosure After Several Interviews Creates Avoidable Risk
A process that withholds pay information through several interviews can frustrate the purpose of Article 5. The applicant may have already spent substantial time on assessments, interviews and preparation without knowing whether the role's pay framework is acceptable. It also weakens the transparency of later negotiation because the employer controls information that should have been available earlier. Even if a particular national rule uses different wording, employers can reduce compliance risk by setting the disclosure point before the first interview rather than testing how late the information can legally be provided.
The Information Is More Than a Bare Number
The applicant's right covers the initial pay or its range based on objective and gender-neutral criteria. Where applicable, relevant provisions of the collective agreement for the position must also be provided. Employers should therefore decide what information package is delivered at the disclosure point. A recruiter who sends an unapproved salary estimate while omitting applicable collective-agreement information may not be following the intended process. The disclosure should come from the same approved pay framework that will govern the employer's later offer and negotiation.
Automate the Disclosure Checkpoint Where Possible
Recruitment systems can make timing compliance more reliable. A vacancy workflow can require an approved pay range before publication, or an applicant-tracking system can prevent an interview from being scheduled until the candidate has received the required pay information. The system can also record the date and method of disclosure. This is more defensible than relying on recruiter memory, particularly for employers handling thousands of vacancies. Automation should still allow country-specific rules where one Member State requires salary information directly in the advertisement.
National Implementation Can Set a More Specific Deadline
The Directive establishes minimum rights, while Member States implement them through national law. A national rule can require the information in the job advertisement, impose additional content requirements or otherwise define the disclosure point more precisely. Employers should therefore maintain local recruitment instructions instead of relying solely on an EU-level summary. A common group policy can set an early baseline, such as vacancy-stage or pre-interview disclosure, and country-specific rules can add stricter requirements where necessary.
Frequently Asked Questions
What is the latest point at which applicants should receive starting pay information?
The Commission describes the rule as disclosure in the vacancy notice or ahead of the interview. Employers should also check whether national law requires an earlier or more specific disclosure point.
Can salary information be provided in an applicant portal?
Potentially, if the method satisfies Article 5's informed and transparent negotiation standard and the applicant receives the information at the required stage under national law.
Should employers keep evidence of when the information was provided?
Yes. Recording the date, method and content of disclosure helps show that the recruitment workflow consistently provides the required information.
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Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.