- What the directive requires in documentary terms
- Terminology that cannot vary between versions
- Why this document type needs a second linguist
- How to prepare the translation process ahead of the 2026 deadline
- How M21Global supports compliance with Directive 2023/970
- Related Services
- Frequently Asked Questions
EU Directive 2023/970 must be transposed into national law by June 2026, and companies with operations across several European countries are already revising their pay policies. Anyone running teams in multiple jurisdictions faces a concrete problem: the same pay policy has to exist in several languages, with the same legal precision in each one. A mistranslated clause on pay progression criteria is not a minor detail. It can trigger a pay discrimination complaint.
The directive requires employers to report gender pay gaps, disclose remuneration criteria and, in certain cases, give workers the right to request information on average pay levels by job category. None of this holds up if the translated version of the policy says something slightly different from the original.
What the directive requires in documentary terms
Covered companies need to prepare and keep current several documents: the pay policy itself, the objective and gender-neutral criteria used to set pay and progression, the pay transparency reports (mandatory for companies with 100 or more employees, with reporting frequency depending on company size) and the internal communications explaining these criteria to staff.
For corporate groups headquartered outside a given country with subsidiaries operating locally, this means translating the pay policy from the headquarters' language into the local language, and often into the languages of other European subsidiaries too. Terminological consistency between versions matters, because any labour authority or employment tribunal will compare the local-language version against what the company actually applies in practice.
Terminology that cannot vary between versions
This is an area where imprecise terminology has direct costs. Some terms that require consistent, technically correct translation:
| Original term | Correct meaning in context |
|---|---|
| Gender pay gap | Difference in average pay between genders |
| Pay transparency report | Mandatory disclosure report under the directive |
| Objective and gender-neutral criteria | Criteria free of direct or indirect gender bias |
| Equal work or work of equal value | Legal standard for comparable job roles |
| Pay progression | Structured salary advancement |
| Joint pay assessment | Employer-employee review triggered by unexplained gaps |
A common error is translating "work of equal value" loosely, losing the legal reference to the comparability standard used across EU employment law and in the directive itself. That weakens the policy in front of a labour inspectorate or in a court proceeding.
Why this document type needs a second linguist
A badly translated pay policy is not just an internal communication problem. It is a document that can be cited in litigation, compliance audits and mandatory reports to regulators. An ambiguous term in a pay progression clause can read as a discretionary criterion, exactly what the directive is designed to eliminate.
This is why this type of content belongs to the category of high-impact documents: contracts, investor communications, compliance reports and internal policies with legal consequences. In M21Global's Estratégica tier, the text goes through a translator, a reviewer and a QA reviewer, follows an ISO 17100 audited workflow, and includes two rounds of post-delivery revision. It is the only one of the company's three service tiers with review by a second linguist (TEP), and it is the right choice for this kind of document, where an error carries direct legal consequences.
Formatting of the final policy, including pay criteria tables and progression grid annexes, is included across all three service tiers, not exclusive to Estratégica.
How to prepare the translation process ahead of the 2026 deadline
A few practices reduce the risk of inconsistency between versions:
- Group all related documents (policy, report, internal communications) into a single translation request, to keep terminology uniform across them.
- Provide an internal glossary if the company already uses specific local-language terms for job categories or pay bands.
- Identify early which countries and languages need translated versions, since companies with subsidiaries in Spain, France or Germany face national transposition deadlines that may not align exactly with each other.
- Allow time for internal legal review of the translated version before it reaches staff.
Skipping this step creates duplicated work later, when legal teams request changes after the translation has already been distributed.
How M21Global supports compliance with Directive 2023/970
M21Global has over 20 years of experience in business translation and has translated more than 445 million words for companies operating across Portugal, Spain, France, Germany, Angola, Mozambique and Brazil. The company is ISO 17100:2015 certified by Bureau Veritas, which ensures an audited process for sensitive documents like pay policies. The business translation page details how these projects are structured according to document type and legal risk, and the article on internationalising your business through translation covers the broader context of multi-country document consistency.
If your company needs to translate its pay policy, progression criteria or the transparency report required under the directive, request a quote from M21Global. You will receive a response within three business hours.
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Frequently Asked Questions
Does Directive 2023/970 require certified translation of pay policies?
The directive does not require certified translation for internal use, but it does require the translated version to accurately reflect the legal criteria of the original, especially for documents that may be submitted to regulators or used in litigation.
Which companies must comply with pay transparency reporting?
The obligation applies to companies with 100 or more employees, with reporting frequency depending on company size, as set out in each country's national transposition of the directive.
Which M21Global tier is suited to translating pay policies?
The Estratégica tier, because it includes review by a second linguist (TEP) and an ISO 17100 audited workflow, is suited to this type of document given the legal impact of an imprecise translation.
Do we need to translate the pay policy into every subsidiary's language?
This depends on the group's structure and national transposition requirements in each country of operation; it is worth confirming the specific deadlines in each jurisdiction before deciding how many versions to produce.
