More than three months past the transposition deadline, only a handful of countries have transposed the EU Pay Transparency Directive (EUPTD). Most employers are preparing against requirements that aren’t yet final.
In our latest webinar, Askin Yasar showed exactly how one enterprise is working through the Directive. Askin, Senior Manager of Global Total Rewards at PepsiCo, runs the company’s EUPTD programme across 20 European countries and roughly 14,000 employees. He walked through how PepsiCo is defining pay, when it notifies workers, and what happens when a request comes in.
Christine Hendrickson, Syndio’s VP of Strategic Initiatives, hosted. Seni Ajamajebi, Syndio’s Regulatory and Reward Domain Expert, brought new survey data from more than 100 global enterprises to show where the market is landing.
Most employers have settled on a strategy. Execution is where it gets hard.
One EU strategy, governed centrally
PepsiCo runs the Directive as a single EU-wide programme with country-level adjustments where required. Askin chairs an EUPTD steering committee with representatives drawn from different countries and functions. The committee aligns the decisions that have to hold across every market, including which payroll elements count toward remuneration and how they map. Local payroll and total rewards teams are consulted before anything is finalised, so country-specific requirements don’t get missed.
Askin summed up what PepsiCo was solving for: “Our objective is to balance the local compliance requirement with a practical, scalable, and operationally efficient EU-wide framework.”
That approach is now the market norm. In a recent Syndio survey, 76% reported running one EU baseline strategy with country-level adjustments where needed. Only 12% are building country by country, and 5% haven’t decided. Live attendees on the webinar answered almost identically, with 67% on the single-baseline approach.
Seni’s read: organisations want the core methodology standardised, with room to adapt as national law diverges. “Employers are standardising that operating model and localising exceptions, rather than creating 27 different programmes,” she said.
Build once, activate as each law takes effect
PepsiCo builds everything once, for all 20 countries, and switches each country on as its law takes effect.
PepsiCo built a dedicated EUPTD website that explains the Directive and outlines employee rights, including a detailed FAQ on the Right to Information process, country-specific legislative references, and local-language content. Each country’s content will roll out only when the Directive is fully transposed. Italy is live. Greece goes into effect in November. The ticketing system works the same way, with a dedicated RTI Request category translated and documented for all 20 countries, available once a country’s law is finalised.
Some countries require a salary range in the job posting. Others only require it to reach the candidate in writing during recruitment. PepsiCo includes the minimum of the salary range in every posting, across all 20 countries once a country’s law is finalised.
“Where salary information must be provided separately to candidates, organisations need to send, track, and retain individual communications as evidence of compliance,” Askin said. “Including the information directly in the job posting removes all those problems. A single approach also reduces the risk of human error.”
PepsiCo’s project team wrote the materials and the key messages, then let local teams deliver them. Every country has different dynamics, employee groups, and communication channels, and Askin’s view was that local teams know those sensitivities better than anyone. They get flexibility on how to communicate, within some governance.
The market has made the same operating decisions. In the Syndio survey, 89% of organisations had already decided how they will notify employees of their right to request pay information, with 77% choosing an intranet portal or direct messaging. But 78% hadn’t yet issued that notice.
As Seni put it, “this is an area where we see strategy ahead of execution.” There is no single right way to handle the Right to Information workflow, because no one process fits every employee population.
Write the criteria for employees, not for the regulator
Article 6 of the Directive requires employers to share how pay is set and how workers progress in their careers. PepsiCo wrote criteria explaining its methodology and built a deck covering pay philosophy, salary planning, and promotion routes, validated by legal. The document is deliberately general rather than country-specific, so one version serves all 20 countries.
PepsiCo put the deck on their EUPTD website alongside the FAQ, then built separate channels for plant employees, who weren’t regularly at the computer.
As Askin explained, “For frontline employees who may not have regular access to online resources, we planned alternative communication channels, including posters with QR codes in our plants, so they can access the information through shared tablets.”
Most organisations already have the underlying job architecture. Fewer have published it. Syndio data shows that 46% have made pay-setting criteria accessible to all workers, while 30% have them defined but not yet shared.
Seni framed the gap between having criteria and sharing them as the real test. “It’s one thing to have it internally,” she said. “It’s another thing to be confident that your criteria are clear, consistently applied, and defensible enough to explain to your workforce.”
Define “pay” before a request forces the answer
The Directive’s definition of pay is broad. PepsiCo mapped every payroll element across 20 countries with local payroll and total rewards teams, sometimes consolidating 10 payroll codes in a single country under one category such as base salary. They then built a standard reporting structure that payroll teams populate monthly.
Standardising pay elements got complicated quickly. Some benefits arrive already annualised. Car allowances in some countries stay at full-time value even for part-time employees. A bonus paid this year may reflect a working arrangement from last year, so a blanket adjustment would double-count it.
“Annualising pay elements to full-time equivalent or a 12-month period may sound really easy and straightforward, but it becomes significantly complex in the details,” explained Askin.
Rather than write per-country, per-element, per-scenario rules, PepsiCo tested a narrower approach against samples of new hires, part-time employees, and employees returning from parental leave. Annualising base salary alone captured roughly 95% of the total remuneration that required annualisation. PepsiCo consulted the Syndio team on the methodology, shared the testing results, and adopted the simpler rule.
The market has not settled this. 32% of organisations in the Syndio survey use actual pay received, 28% annualise, and 26% use a mix by component. What you decide matters less than why.
As Seni advised: “You need to produce the same answer to the same question every time. Have you made a deliberate and repeatable decision that works for your pay structure and your employee population? And have you documented why you made that decision?”
Prepare for the requests before they arrive
Before Italy went live, PepsiCo ran the analysis in reverse. The team pulled individual gap reports from the Syndio platform to find employees sitting well below their peer average. As Askin explained, “These reports show individual pay gaps compared to peers and often show the employees most likely to raise questions when they receive their figures.”
When we identified employees who are significantly lower than peer average in Italy, local comp teams reviewed each case, documented the underlying reasoning, and prepared talking points for HR business partners. If one of those employees asks, the conversation will be straightforward, because the answer had been worked out weeks earlier. PepsiCo is running the same analysis ahead of Greece. A dedicated shared service team handles incoming tickets, attaching a thorough FAQ in English and local language to each response.
Volume so far is low. Around 5% of PepsiCo’s in-scope Italian employees have submitted a request. Across the Syndio survey, 61% of organisations had received no requests at all where the law is in effect. In countries where the law is not yet in force, two organisations already fielded requests from more than 30% of their workforce, and 25% have received at least one request.
Seni cautioned against reading the low volume of requests today as a measure of readiness. The better question, she said, is whether the volume increasing tomorrow would break anything. Could you respond consistently, protect employee privacy, and manage the workflow at scale?
Get ahead of the 2027 reporting deadline
The first reporting cycle does not begin until mid-2027, and not every country will be in scope even then. PepsiCo is not waiting. “My view is that organisations don’t need to wait until reporting becomes mandatory,” said Askin.
With the goal of finding problems while there is still time to fix them, his team is analysing 2026 data in two phases:
- First, base salary in the Syndio platform, to identify outliers and find which levels or categories of workers show gaps;
- Second, total remuneration, using actual payroll files from January through June.
Their goal is to close the pay gaps as early as possible. For now, that means the next pay cycle instead of after a report is published. Eventually it means catching them at the decision itself, before pay gaps are created in the first place.
Listen to the full conversation
If you can’t yet say which definition of pay you’ll use, when your annual notice goes out, or what happens when the first request arrives, you are not behind the market. Most organisations are working through the same list right now.
Watch the replay to hear how PepsiCo is leading the market with their strategy, what the annualisation testing turned up, and how to plan for 2027 while the rules are still moving.
The information provided herein does not, and is not intended to, constitute legal advice. All information, content, and materials are provided for general informational purposes only. The links to third-party or government websites are offered for the convenience of the reader; Syndio is not responsible for the contents on linked pages.
