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EU PAY TRANSPARENCY DIRECTIVE COMPLIANCE FOR PORTFOLIO COMPANIES
The Directive doesn’t care how many companies are in your portfolio.
Every one of them has to comply.
Multiple portfolio companies. Multiple countries. Zero common pay frameworks. And a reporting deadline that uses this year’s data. Non-compliance doesn’t just mean fines. It means remediation costs that hit EBITDA, litigation exposure that surfaces during due diligence, and a governance gap that every serious buyer or LP will find. Europe HR Solutions gets PE and VC-backed portfolio companies compliant across all European entities – fast, structured, and without rebuilding compensation from scratch.
What We Deliver
EUPTD Compliance Across Your European Portfolio – From Assessment to Remediation
Europe HR Solutions supports PE and VC funds and their portfolio companies in meeting the EU Pay Transparency Directive requirements across multiple European entities. We combine local compensation expertise with practical, portfolio-scale execution, so compliance doesn’t become a 12-month consulting engagement that outlasts the deadline.
Unlike Big 4 firms that scope EUPTD as a transformation project, we deliver focused, operational compliance: assess, remediate, report. Unlike compensation software vendors, we don’t sell a platform and hope you figure out the regulatory nuance in each country. We do both – the regulatory interpretation and the operational fix.
Pay gap assessment across all portfolio entities
Gender-neutral job architecture and grading frameworks
Country-specific regulatory interpretation and compliance mapping
Recruitment transparency and salary history policy alignment
Reporting structure design for 2027 filing requirements
Why EUPTD Compliance Is Harder for PE/VC Portfolio Companies
Every entity was acquired separately. Every one runs its own pay logic. The Directive doesn’t offer a portfolio-level exemption and it doesn’t care that nobody at the fund level has ever looked at these structures side by side.
Every entity has different pay structures and different data
Portfolio Company A uses a Radford framework. Company B has no formal grading at all. Company C inherited pay bands from its previous parent. Company D has collective agreement scales in Germany and ad hoc structures everywhere else. Each uses a different payroll provider, different job titles, different compensation elements. The Directive requires gender-neutral, comparable pay data across all of them. You can’t report what you can’t compare and right now, you can’t compare.
The 5% gap triggers a works council process nobody has started
If the gender pay gap within any worker category exceeds 5%, the employer must conduct a joint pay assessment with employee representatives, meaning works councils in Germany, France, Belgium, and the Netherlands. For portfolio companies that have never engaged a works council on compensation matters, that’s a formal consultation process that takes 3–6 months before you can even begin remediation. If you haven’t started, you’re already behind.
Recruitment transparency obligations start on day one
From June 2026, every job posting for a European role must include a salary range, and employers cannot ask candidates about their salary history. Portfolio companies that haven’t defined pay ranges or published compensation criteria will be non-compliant from the first hire after the enforcement date. This isn’t a reporting obligation you can prepare for over 12 months – it’s immediate.
The burden of proof shifts to the employer
Under the Directive, if a pay transparency obligation is breached, the burden of proof shifts to the employer. The employee no longer needs to prove discrimination – the employer must prove there is none. For portfolio companies with weak documentation, inconsistent grading, and no formal pay-setting criteria, this creates significant litigation exposure.
The first hire you make after June 2026 without a published salary range is already a compliance breach. The first reporting period uses 2026 pay data. The clock is running.
Pay Gap Assessment Across All Entities
We assess the gender pay gap across every European entity in your portfolio – by country, by worker category, by compensation element. We identify where you exceed the 5% threshold and what’s driving it. The output is a prioritized risk map your operating partners can act on immediately.
Job Architecture & Grading Framework
We build or align gender-neutral job architectures across portfolio entities so compensation is structured, comparable, and defensible. This isn’t a 6-month HR transformation. It’s a pragmatic framework designed to meet the Directive’s requirements without overengineering what already works.
Country-Specific Regulatory Mapping
Each EU member state is transposing the Directive differently. Germany, France, the Netherlands, Belgium, and the Nordics are all on different timelines with different local requirements. We map the regulatory landscape for every country your portfolio operates in and tell you exactly what each entity needs to do, by when.
Recruitment Compliance & Policy Update
We update hiring practices, job posting templates, and internal policies to comply with the Directive’s pre-employment transparency requirements – salary range disclosure, salary history ban, and pay-setting criteria documentation. Ready to use from day one of enforcement.
Reporting Structure & 2027 Filing Preparation
We design the reporting framework your portfolio companies need to file gender pay gap reports by the 2027 deadline (using 2026 data). This includes defining worker categories, standardizing data formats across entities, and establishing the process for annual or triannual reporting based on headcount thresholds.
WHAT’S REALLY AT STAKE
EUPTD Non-Compliance Is a Deal Risk - Not Just a Fine
When your portfolio company goes to market, for a secondary, a trade sale, or a new fundraise, the buyer’s HR due diligence will now include EUPTD compliance. Can the company produce pay gap data? Is there a defensible job architecture? Are recruitment processes compliant? If the answer is no, it becomes a price chip, a condition precedent, or a reason to walk.
The Directive also creates a new vector for employee claims. If a portfolio company has been paying women less for equivalent work and can’t demonstrate objective justification, the burden of proof is on the employer. Back pay, damages, and legal costs become quantifiable liabilities – the kind that show up in vendor due diligence reports and kill deal certainty.
We help you close this exposure before it becomes a deal problem. Fund-level assessment, entity-level remediation, reporting readiness – one engagement, all entities, before the next exit process begins.
How It Works
From Portfolio Diagnostic to Reporting-Ready in Weeks, Not Months
Weeks 1–3: Portfolio-Wide Diagnostic
We map every European entity in your portfolio – headcount, countries, payroll providers, compensation structures, and existing job grading (if any). We identify which entities are in scope for reporting, where the 5% gender pay gap threshold is most likely being breached, and which countries have already transposed the Directive. You get a single, consolidated risk view with entity-by-entity prioritization.
Weeks 4–8: Entity-Level Implementation
Starting with the highest-risk entities, we build or align job architectures, document pay-setting criteria, run pay gap calculations, and update recruitment policies. Each entity gets what it needs – pragmatic, compliant, defensible. Entities with existing frameworks get adapted. Entities with nothing get a fit-for-purpose structure built from the ground up.
Ongoing: Reporting, Monitoring, and Compliance Support
We design the reporting process for the 2027 filing deadline – data collection, worker category definitions, gender pay gap calculations, and joint pay assessment triggers. After filing, we stay as your retained compliance partner: monitoring regulatory changes across countries, managing employee pay information requests, and updating frameworks as your portfolio evolves through new acquisitions and exits.
Trusted by Companies Managing Complex European HR Across Multiple Entities
We help PE and VC-backed companies navigate European compensation compliance, close pay transparency gaps, and meet regulatory deadlines across every entity in their portfolio.
We’ve been working with EHRS for a long time and it’s always the same pleasure to work together. Thank you for your confidence, your enthusiasm and your professionalism!
Lionel Paraire
Associate Director
Working with EHRS has helped the wider HR team in managing workloads, and our partners are starting to see the benefit of this relationship.
Paula Stillman
Head of HR
These experts are incredibly knowledgeable and professional. I can contact them and feel confident in knowing that I will receive accurate guidance.
Jess Clark
Employee Relations Specialist
WHY WORK WITH EUROPE HR SOLUTIONS
Your Partner for EUPTD Compliance Across European Portfolios
Most compensation consultants approach the EUPTD as a single-entity project. For PE and VC funds, the challenge is exponentially harder – multiple entities, multiple countries, no common framework, and one deadline.
We work at both the fund level and the entity level, giving operating partners portfolio-wide visibility while delivering entity-specific compliance.
Pan-European Compensation & Labor Law Expertise
Local specialists across 30+ European jurisdictions who understand both the Directive’s EU-wide framework and how each country is transposing it. We don’t give you generic guidance. We tell you exactly what each entity in each country needs to do.
Portfolio-Scale Execution, Not Consulting Theater
We deliver compliance, not slide decks. Pragmatic job architecture. Actionable pay gap remediation. Reporting frameworks that work. At a pace and price point that fits PE/VC portfolio operations, not a Big 4 engagement that costs more than the fine.
One Partner Across All Entities and Countries
Instead of each portfolio company hiring its own local advisor in each country, you engage EHRS once at the fund level. We coordinate compliance across every entity and every country through a single point of contact.
From Assessment to Ongoing Compliance
The team that assesses your portfolio’s EUPTD exposure is the same team that builds the fix and supports ongoing compliance – reporting, employee information requests, recruitment policy updates. No handoff, no knowledge loss.
Frequently Asked Questions About the EU Pay Transparency Directive for Portfolio Companies
Does the Directive apply to every company in our portfolio, or only the larger ones?
Core obligations – salary range disclosure, salary history ban, employee pay information rights – apply to all employers regardless of size from June 2026. Gender pay gap reporting kicks in from 2027 for 150+ employee entities and 2031 for 100+. Even your smallest European entity must comply with the transparency rules from day one.
Our portfolio companies were acquired at different times and have completely different pay structures. Is that a problem?
It’s the central problem. The Directive requires comparable, gender-neutral pay data, and you can’t compare across entities that don’t share a common framework. We build pragmatic alignment without starting from scratch.
What happens if a portfolio company has a gender pay gap above 5%?
Mandatory joint pay assessment with employee representatives, corrective measures within six months, and if you can’t justify the gap – financial penalties, back pay claims, and potential public procurement exclusion. The burden of proof is on the employer.
We don't have consistent payroll data across our portfolio. How do we report?
Inconsistent data isn’t an exception. It’s just a harder problem to solve before the deadline. We standardize job categories, align compensation elements, and consolidate payroll data into a reportable format. The first reporting period uses 2026 data, so the consolidation work needs to happen now.
Can we handle this at the fund level, or does each portfolio company need to comply separately?
Compliance is per entity – the Directive applies at the employer level, not the fund level. But strategy, framework design, and coordination should absolutely sit with operating partners. One EHRS engagement covers the entire portfolio.
How quickly can you assess our portfolio's EUPTD exposure?
3–4 weeks for a full portfolio diagnostic. You get a consolidated risk view showing which entities are in scope, where data gaps exist, and where the 5% threshold is most likely being breached. Entity-level implementation is prioritized from there.
We're planning an exit for one of our portfolio companies. Does EUPTD compliance affect the deal?
Yes, and increasingly so. Buyer-side HR due diligence now includes pay transparency compliance as a standard check. Unresolved pay gaps, missing job architectures, and non-compliant recruitment practices become quantifiable liabilities in the vendor due diligence report. Getting compliant before the process starts removes a negotiation chip and protects deal value.
Get your portfolio EUPTD-ready. Start with a conversation.
Set Up Your Portfolio’s EUPTD Compliance the Right Way
Whether you’re an operating partner managing compliance across multiple European entities, a portfolio company CHRO preparing for reporting, or a fund-level compliance lead assessing portfolio-wide exposure – a short conversation can bring clarity.
We’ll help you understand what each entity needs, which countries carry the highest risk, and how to sequence the work so you hit the 2027 reporting deadline without scrambling.
No obligation. No pressure. Just clear, practical guidance.