Pay transparency in job adverts - what's actually happening, and how to have your say

I saw the headline that salary disclosure is set to become compulsory in job adverts the other day. My knee-jerk reaction was to crack open the prosecco and dance round the kitchen table. Sensible Jen kicked in before I reached the fridge, because "compulsory" was doing a lot of work a government consultation had not caught up with yet.

Here is what is actually happening, what the evidence says about what happens when this kind of law passes elsewhere, and what you can do if you want to have a say.

The facts

• The Cabinet Office has published draft proposals as part of a wider reform of the Equal Pay Act, the UK's core equal pay law, in place since 1970

• Core requirement: publish pay and conditions in every job advert, or hand it over in writing before interview if there is no advert

• This is a consultation, called "Equal pay and pay discrimination", not a law yet. It runs 15 weeks and closes at 5pm on 27 October 2026

• After that, ministers review responses, then set detailed rules for England, Scotland and Wales, followed by a long implementation process

• Right now, only around one in five UK employers publish salary voluntarily

How to have your say

This is the part most coverage of this story leaves out: you can respond directly, and not just as an employer. The government wants views from employers, trade unions, public sector bodies, women's sector, race and disability stakeholders, legal experts, and individuals with direct experience of pay discrimination.

To respond:

• Read the consultation document, "Equal pay and pay discrimination"

• Submit your answers through the online survey, or email equalpayconsultation@cabinetoffice.gov.uk if you would rather

• Deadline: 5pm, 27 October 2026

The UK already has a version of this, and it worked

Before we even get to other countries, the UK already runs something in this family. Since 2017, employers with 250 or more staff have had to publicly report their gender pay gap. A UCL study looked specifically at financial services, where the gap tends to run wider than average, and found:

Before the rule: women earned around 19 percent less than men on average in financial services

• After the rule: that had narrowed to around 13 to 14 percent, a 25 to 30 percent reduction in the size of the gap itself

• Nationally, the same pattern shows up: the UK's median gender pay gap fell from 16.8 percent in 2016 to 13.3 percent in 2023

• Companies that kept reporting through a pandemic enforcement pause had gaps around 6 percent smaller than those that stopped, suggesting transparency itself does real work, not just fear of a fine

That is a different mechanism to what is being proposed now, aggregate company reporting rather than salary ranges in individual adverts. But it proves the UK already has a working precedent.

Denmark backs this up, Austria is a useful counter-example

Denmark requires companies with 35 or more staff to report sex-disaggregated pay data, or run an equal pay audit instead. Its gender pay gap sat at around 18 to 19 percent before the law, similar to the UK's financial services gap, and it narrowed by around 2 percentage points afterwards, down to somewhere around 16 to 17 percent. A smaller effect than the UK's, but real, and companies near the threshold hired and promoted more women than smaller firms not yet covered.

Austria is the useful counter-example. Its 2011 law required larger firms to publish internal gender pay gap reports. A study comparing outcomes before and after the law took effect (what economists call an event-study design) found it made essentially no difference. Even at the outer edge of what the researchers could detect, the gap moved by no more than 0.4 percentage points, in effect a rounding error, with no wage compression either.

The likely reason: Austria's numbers stayed internal to the company, reviewed quietly rather than acted on by anyone outside it. The UK's rules, Denmark's, and the new job advert proposal all put information directly in front of the people who can act on it, candidates and employees. That difference looks like it matters more than whether a transparency law exists at all.

Colorado is the closest match to the actual proposal

Colorado's Equal Pay for Equal Work Act has required salary ranges in job postings since 2021, the closest existing law anywhere to what is being proposed here. A 2025 study by economists Arnold, Quach and Taska found:

• Posted wages rose 3.6 percent in Colorado after the law

• Self-reported wages (via Glassdoor) rose 1.3 percent overall, 1.8 to 3.0 percent for new hires

• Official state wage data showed similar 1.3 to 1.4 percent increases across other states with comparable laws

• Wage gains reached even companies that already disclosed salaries voluntarily, suggesting it raised competition market-wide, not just at newly transparent employers

• No drop in job postings or employment, and no increase in required qualifications, so employers did not get pickier or hire less

• Employers largely did not post artificially wide, meaningless ranges to dodge the law's spirit

• Compliance rose from around 35 percent to around 70 percent within a year, though roughly one in five postings still skip it now, plain non-compliance looks like the bigger practical risk, not clever loopholes

To be upfront: Colorado is a US state, and US and UK compensation are not built the same way. A few reasons the wage percentages do not translate directly:

The US has no federal statutory minimum paid leave at all, it is the only country in the OECD (a group of 38 mostly high-income countries, including the UK, that compare economic and social policy) without one

• The UK guarantees 28 days by law, and UK office workers get roughly 30 percent more paid time off on average than US counterparts

• Health insurance is often tied to employment in the US in a way it simply is not here, thanks to the NHS

So a headline wage percentage from a US study is not automatically comparable to what the same percentage would mean in the UK, salary carries a different share of someone's total compensation depending on what else is guaranteed around it. The more portable findings are probably the behavioural ones, employers did not shrink hiring or dodge the law, since those are about how employers act under a new rule rather than currency or benefits structures. I work across both markets, so this is not a reason to dismiss the US data, just a reason not to read the wage percentages as a straight prediction for the UK.

It narrows the gender pay gap in negotiations, but does not close it on its own

Research from the University of Delaware found that in salary negotiations, men asked for close to 17,000 dollars more than women on average when no salary information was available. Give both comparably qualified salary information, and that gap nearly disappeared. Show candidates salary information for more qualified people instead, and a gap of around 5,000 dollars remained. Transparency closes an information gap, it does not remove every other factor at play in a negotiation.

It appears to reduce stress too, and this is UK data

A study using the Workplace Employment Relations Study, or WERS, a large, government-backed survey of UK workplaces run periodically since the 1980s, covered 15,747 workers across roughly 2,500 UK workplaces. Employees at more financially transparent employers reported around 15 percent lower job-related stress, a bigger effect than gender or income differences had on stress.

This measured openness about budgets and profits generally, not salary ranges specifically, so it is suggestive rather than proof that pay transparency alone produces the same effect. Taken together with the UK's own pay gap reporting results though, it points the same way, openness about money at work seems to change how people feel about their employer, not only what they are paid.

Not all transparency is the same, and that matters

A widely cited study on California city managers found that making individual salaries fully public, the actual named number for each named person, rather than a range, triggered real consequences: pay cuts for the highest earners of 7 percent on average, a 75 percent jump in quits, and longer vacancies when replacing people.

That is a genuinely different kind of transparency to what is proposed here, publishing a salary range before anyone is hired, rather than publishing what a specific, already-employed person earns. It is worth knowing, because this study gets used to argue against the UK proposal even though it describes a different policy entirely.

Benefits to candidates and employees

You stop wasting time applying and interviewing for roles that were never going to match your expectations

• Real wage gains showed up in practice in Colorado, pay rose, it did not fall, after the law came in

• The UK's own pay gap reporting rules produced a real, measurable narrowing of the gender pay gap since 2017

• It narrows the pay gap in negotiations for comparably qualified people

• It reduces the psychological weight of guessing, openness on pay is linked to lower reported job stress

• It levels the playing field for people less comfortable negotiating, or new to a market or industry

Benefits to companies

No evidence transparency shrinks the hiring pool, postings, employment and requirements all stayed steady in Colorado

• Companies near Denmark's reporting threshold hired and promoted more women, not fewer

• Wage gains reached companies that already paid fairly and disclosed voluntarily, so being transparent early is a competitive advantage while roughly four in five UK employers still are not

• Reduces legal and reputational risk tied to unfair or inconsistent pay decisions

• A genuine opportunity to show current staff, not just candidates, that they are valued

Potential drawbacks, and how companies might try to get around it

• Simple non-compliance is the realistic risk, not clever loopholes, roughly one in five Colorado postings still skip it a year on

• Posting an artificially wide, meaningless range is the fear most people raise, but Colorado's employers largely did not do this in practice

• Individual negotiation may feel more constrained once a range is public, and some research on full salary disclosure, not ranges, shows real pay compression at the top for the highest earners

• Genuine administrative burden for companies without formal pay structures already in place, a real cost, not just an excuse

• Existing staff may feel friction seeing external ranges that do not match their own pay, a commonly raised employer concern rather than something with a dedicated study behind it, but worth taking seriously, particularly for long-serving staff whose pay has not kept pace with the market

• Recruitment industry voices have raised concerns about government "interference with commercial relationships", and employment lawyers have flagged ripple effects into pay governance, compliance and outsourcing arrangements

• Austria's experience is a reminder that a transparency law is not automatically effective, if the information stays internal rather than reaching the people who can act on it, it can change very little

• Enforcement matters as much as the rule itself, when the EU introduced its own pay transparency directive, only four member states met their implementation deadline

My take

Even with the uncertainty, I think the direction of travel is right.

Candidates deserve exactly the same respect as anyone else in a hiring process, and their time matters just as much as a hiring manager's or an HR professional's. Companies can advertise a role, interview five people and make an offer, but they cannot fill it unless a candidate says yes. Treating a candidate's time like it does not matter, making them apply blind and find out three interviews in that the number was never going to work, never made sense to me.

Transparency also works the other way. It pressures companies to actually look at their own pay structures, make sure they are fair, and make sure salaries reflect proven skill and capability rather than leaving high performers underpaid because nobody checked. I think it could reduce staff turnover too, people are more likely to stay somewhere with a clear progression route and a genuine sense of where they stand in the market. Pay transparency is not a threat to good employers, it is a chance to show staff they are actually valued.

The prosecco is staying on ice until it is actually law.

Sources

• Arnold, Quach and Taska, "The Impact of Pay Transparency in Job Postings on the Labor Market", NBER (National Bureau of Economic Research) Working Paper (2025), and reporting in Colorado Newsline

• Obloj and Zenger, "Research: The Complicated Effects of Pay Transparency", Harvard Business Review (2023)

• Sleesman et al., University of Delaware research on salary information and negotiation gender gaps, reported via HR Dive

• Workplace Employment Relations Study data, published in Social Science Research (2021), reported via Ohio State News

• Mas, "Does Transparency Lead to Pay Compression?", Princeton University working paper, on California city manager salary disclosure

• UCL, "How effective has mandatory pay gap reporting been at reducing the gender wage gap"

• World Bank Blogs, "Pay transparency policies can reduce the gender pay gap: the case of Denmark and the United Kingdom"

• Böheim and Gust, "Does Pay Transparency Affect the Gender Wage Gap? Evidence from Austria", American Economic Journal: Economic Policy

• Holiday Entitlement Calculator, "UK vs US Holiday Entitlement 2026", for statutory leave comparison

• Lewis Silkin, "UK pay transparency in recruitment: pay ranges in job adverts are under consultation" (July 2026)

• GOV.UK, "Equal pay and pay discrimination" consultation page

• SmartSurvey, the direct online response form for the consultation