A Deadline That Cannot Be Ignored
On 7 June 2026, the EU Pay Transparency Directive (2023/970/EU) must be fully transposed into the national law of every EU member state. For companies hiring in Cyprus — one of Europe's largest fintech and regulated financial services hubs — this is not a future concern. It is happening now.
If your company is based in Cyprus, hires employees under Cypriot employment law, or posts job vacancies targeting candidates in the EU, the rules have changed. This guide explains exactly what has changed, what you need to do, and what happens if you do not.
What Is the EU Pay Transparency Directive?
The EU Pay Transparency Directive (Directive 2023/970/EU) was adopted by the European Parliament and Council in May 2023 and entered into force in June 2023. Member states had three years — until 7 June 2026 — to implement it into national legislation.
The directive is designed to address the gender pay gap across the EU, which currently stands at approximately 13% on average. It does this by requiring greater transparency about how employers set and communicate pay — making it harder to maintain discriminatory pay structures in secret.
For most fintech companies in Cyprus, the gender pay gap implications are secondary to the immediate operational impact: you must now disclose salary information when you advertise a job.
The Five Key Requirements That Affect Your Hiring Process
1. Mandatory Salary Disclosure in Job Postings
This is the change that affects almost every company immediately.
Before the directive, it was standard practice across the fintech industry — and in Cyprus specifically — to advertise roles with vague salary language: "Competitive", "Attractive package", "To be discussed", "Dependent on experience." Under the directive, this is no longer compliant.
What the directive requires: Job postings must include either:
- A specific salary figure, or
- A salary range (minimum to maximum) that the employer genuinely intends to pay
The salary information must be provided in the job advertisement itself or at the latest before the first interview. Providing it only at the offer stage is not sufficient.
What this means in practice for fintech companies in Cyprus:
| Previous practice | Compliant under directive? |
|---|---|
| "Salary: Competitive" | No |
| "Salary: Attractive package, DOE" | No |
| "Salary: To be discussed at interview" | No (if not disclosed before first interview) |
| "Salary: €3,500 – €5,000 net/month" | Yes |
| "Salary: €4,500 net/month + performance bonus" | Yes |
| "Salary range provided before first interview upon request" | Borderline — risky |
The directive does not specify whether the salary must be net or gross — but it must be specific enough to be meaningful. A range of "€2,000 – €10,000" that effectively covers every possible salary would not meet the spirit of the requirement.
2. Ban on Salary History Questions
Employers — and recruitment agencies acting on their behalf — are prohibited from asking candidates:
- What they currently earn
- What they earned at previous employers
- What their salary expectations are based on their previous earnings
This is a significant shift for an industry where salary benchmarking based on current compensation has been standard practice. The rationale is that basing new salary offers on historical earnings perpetuates existing pay gaps — particularly affecting women and candidates who have moved between markets with different salary levels.
What you can still ask:
- What the candidate's salary expectations are for this specific role
- Whether the advertised salary range meets the candidate's requirements
What you cannot ask:
- "What are you currently earning?"
- "What were you earning at your previous employer?"
- "What was your salary package at [previous company]?"
For fintech HR managers, interview scripts and assessment processes need to be updated to remove these questions.
3. Employee Right to Pay Information
Existing employees now have a legal right to request:
- Their individual pay level relative to comparable roles
- The average pay levels for comparable roles within the company, broken down by gender
Employers must respond to these requests within two months. Refusing to respond or providing incomplete information is a breach of the directive.
Crucially — employers cannot prohibit employees from discussing their salaries with colleagues. Pay secrecy clauses in employment contracts that prevent salary disclosure between employees are no longer enforceable.
4. Pay Reporting Obligations
Larger employers have additional reporting obligations under the directive:
| Company size | Reporting obligation |
|---|---|
| 250+ employees | Report gender pay gap annually from 2027 |
| 150–249 employees | Report every 3 years from 2027 |
| 100–149 employees | Report every 3 years from 2031 |
| Under 100 employees | No mandatory reporting (but transparency rules still apply) |
For most fintech companies in Cyprus — which tend to have fewer than 100 employees — the reporting obligation does not apply immediately. However the salary disclosure and pay information rights do apply from day one regardless of company size.
5. Joint Pay Assessment for Significant Gender Pay Gaps
Where an employer's pay reporting reveals a gender pay gap of more than 5% that cannot be justified by objective, gender-neutral factors, the employer must conduct a joint pay assessment in cooperation with employee representatives.
This is primarily relevant for larger firms and less immediately pressing for most fintech companies in Cyprus — but it underlines the direction of travel: pay transparency is not a one-time disclosure exercise, it is an ongoing compliance obligation.
What This Means Specifically for Fintech Companies in Cyprus
Cyprus is home to hundreds of CySEC regulated investment firms, forex brokers, payment institutions, iGaming companies, and crypto firms. The fintech sector in Limassol alone employs tens of thousands of people from across the EU and beyond.
The pay transparency directive has several specific implications for this community:
Salary disclosure on job postings is now required. If you are posting a role for a Compliance Officer, Sales Manager, MT4/MT5 Administrator, or Head of Dealing — you must include the salary range. The days of "Competitive" as a complete salary description are over for EU-based employers.
This affects your recruitment agency relationships. If you engage a recruitment agency like HRFinEase to fill roles on your behalf, you need to instruct the agency on what salary range to disclose. The employer remains responsible for compliance — but the practical implication is that you need to agree on a disclosed range before the search begins.
Confidential salary structures require careful handling. Some fintech firms prefer not to disclose salary ranges publicly for competitive reasons — they do not want competitors knowing what they pay for specific roles. The directive does not prevent this entirely, but it requires that the information be provided to candidates before the first interview. A practical approach is to provide the range in the initial recruiter briefing, which is then disclosed to shortlisted candidates before screening calls.
Employment contracts and HR processes need updating. Pay secrecy clauses need to be removed. Interview scripts need to eliminate salary history questions. HR teams need to be trained on the new rules.
Non-EU candidates applying for Cyprus roles are also covered. The directive applies based on the employer's location and the applicable employment law — not the candidate's nationality or location. A candidate in Ukraine applying for a role at a CySEC firm in Cyprus is covered by the directive.
The Practical Steps to Take Now
If your company is hiring in Cyprus, here is what to do immediately:
Step 1 — Audit your current job postings Review all active job postings. Any that use "Competitive", "TBD", or similar vague salary language need to be updated with a specific range. This applies to postings on your website, LinkedIn, job boards, and any postings managed by recruitment agencies on your behalf.
Step 2 — Establish internal salary bands The directive effectively forces companies to articulate what they are actually willing to pay for each role. If you do not have formal salary bands, now is the time to create them. This is an opportunity to build a more structured, defensible pay structure.
Step 3 — Update your interview process Remove all salary history questions from interview scripts, recruiter briefing templates, and assessment frameworks. Replace with questions about the candidate's expectations for this specific role.
Step 4 — Review employment contracts Check for pay secrecy clauses that prohibit employees from discussing their salaries. Remove or amend these clauses — they are no longer legally enforceable.
Step 5 — Brief your recruitment partners If you use external recruiters, brief them on the salary range you are willing to pay for each role and confirm that this range should be disclosed to candidates before first contact or screening.
Step 6 — Prepare for employee pay information requests Ensure you have a process in place to respond to employee requests for pay information within the two-month deadline. This requires having clear data on what comparable roles are paid within your organization.
How HRFinEase Is Adapting
At HRFinEase, we are updating our processes to support full compliance with the directive for all roles we manage on behalf of clients:
- All new vacancy postings will include a salary range or specific figure as instructed by the client employer
- Where clients instruct us to maintain salary confidentiality, we will disclose the range to shortlisted candidates before the first screening call — satisfying the "before first interview" requirement
- Our job posting form has been updated to include salary range as a required field, with guidance on the directive's requirements
- We will not ask candidates about their current or previous salary during our screening process — only about their expectations for the specific role
If you are a company currently working with us or considering doing so, please ensure you brief us on the salary range for each role at the start of the engagement. This is now a compliance requirement, not just a preference.
A Note for Candidates
The directive significantly strengthens your position as a candidate in the EU job market:
- You have the right to know the salary range before your first interview — if an employer does not provide it, you can ask and they must tell you
- No employer can legally ask what you currently earn or have earned previously
- If you are already employed, you have the right to ask your employer how your pay compares to colleagues in comparable roles
- Pay secrecy clauses in your contract that prevent you from discussing your salary with colleagues are no longer enforceable
At HRFinEase, all salary information for the roles we manage is available to candidates before the first interview. Submit your profile at hrfinease.com/candidates and our team will provide full role details including salary ranges from the first conversation.
The Bottom Line
The EU Pay Transparency Directive is not optional, and the June 7, 2026 deadline is not a suggestion. For fintech companies hiring in Cyprus — whether you are a CySEC regulated broker, a payment institution, an iGaming operator, or a crypto firm — the rules around salary disclosure and salary history questions have fundamentally changed.
The companies that adapt quickly will find that pay transparency is not just a compliance exercise — it is a competitive advantage. Candidates respond positively to employers who are upfront about compensation. Job postings with clear salary ranges consistently receive more applications from better-qualified candidates than those with vague language.
If you need help structuring your salary bands, updating your recruitment process for compliance, or finding candidates for roles where you now need to commit to a disclosed salary range — HRFinEase is here to help.
Contact HRFinEase:
- Email: info@hrfinease.com
- Phone: +357 96946094 (WhatsApp / Telegram available)
- Post a vacancy with salary disclosure
- Submit your candidate profile
- View our fee schedule