EU Directive 2023/970 on pay transparency is not “just another regulation” to file away among bureaucratic paperwork. The countdown has started — and it allows no distractions. It marks a cultural and legal turning point that is about to hit every Italian company with the force of a hurricane.
Soon, the very concept of “pay secrecy” will disappear. Every employee will have the legal right to request — and obtain — clear, detailed, and objective information on the average pay level of workers performing work of equal value. If today the question, “Why does he earn more than I do?”, is still whispered in the corridors, tomorrow it will become a formal request placed on the desk of HR or the business owner, backed by European law.
The risk of an unstructured approach: a trap for entrepreneurs
Faced with this deadline, many companies are making a critical mistake. They are acting in an unstructured way and aiming only for short-term, cosmetic compliance in order to avoid immediate penalties. They limit themselves to filling in Excel sheets that are disconnected from any deeper logic, hoping simply to pass the next audit.
This approach makes no sense. More importantly, it is extremely dangerous.
An improvised system does not answer the real question: “Why?” Without a solid methodology behind it, every explanation given to an employee will sound like an excuse or disguised favoritism. This fuels frustration, demotivation, and legal disputes that can cost tens of thousands of euros. Trying to justify, after the fact, years of pay policies shaped by urgency or by the bargaining power of individual employees is a monumental task. It chases chaos without ever bringing it under control.
The anxiety of the difficult conversation and the weight of company history
We hear the same concern from entrepreneurs every day: the fear of being unprepared when a valuable employee asks for transparency. This uncertainty keeps companies in a constant state of alert. It also freezes compensation decisions, out of fear of creating dangerous precedents or unconscious discrimination. This is a climate that stifles growth and damages the working environment.
We bring objectivity to the historical distortions of corporate systems, which often arose for many understandable reasons: a shortage in the labour market, an unexpected emergency, individual negotiations at a critical moment, or simply seniority. We do not judge that past. We understand it. But we also know that, today, it must be reorganised in order to protect the company’s future.
The EDA Method: the framework that rationalises value
We do not step in to analyse corporate disorder and laboriously attempt to rationalise it — a process that would require months of interviews and extremely high costs. We arrive with what we call a “mould in the sand”: the EDA Method (Equity Driven Architecture).
Think of it as a pre-set, scientific, and objective architecture that we apply over the organisation. Instead of chasing exceptions created by the past, we define the rule for the future from the outset. Once those past choices are positioned within the EDA framework, they finally find a logical structure. The rules are set with great ease, while the exceptions are identified, understood, and brought back into a conscious and sustainable management plan.
Scientific evidence: how EDA meets the requirements of EU law
To ensure full compliance, we have mapped the parameters of the EU Directive into our methodological drivers, drawing inspiration from the Hay model.
Click here to see how each legal requirement is met.
A smooth transition and simpler management
What does not fit perfectly into the framework today is not forced into place. It is identified and managed over time through financial adjustment plans and targeted management policies that respect the company’s cash flow.
Once the EDA system has been implemented, every HR process becomes significantly simpler and more automatic.
- Pay review decisions — Budget allocation becomes clearer. This allows merit to be rewarded without undermining internal equity.
- Career progression — Advancement becomes a clear transition to higher grades, based on defined requirements.
- Retention and engagement plans — Critical talent can be protected on the basis of real market data.
- MBO, welfare, and flexible benefits — Incentives and benefits can be calibrated according to the actual weight of the role, making the company more competitive and attractive.
Digital speed: software and assessment tools
Time is valuable for everyone. Through proprietary software and digital assessment tools, we drastically accelerate the mapping process. We reduce the margin of error and provide intuitive dashboards — including Red and Green Circles — that allow management to monitor the Gender Pay Gap and EU compliance in real time.
Training and communication: the core of the project
A system cannot work without people. Our intervention always includes targeted training for internal teams, so that HR departments and entrepreneurs can operate independently. We also design internal communication plans. We provide managers with practical scripts to explain pay ranges to their teams, turning transparency from a threat into a tool for trust and engagement.
The same applies to recruiters, because the market is the other major pressure companies must face: candidates also expect coherent and credible communication about salary ranges.
The final seal: trust in the method
Why can companies rely on the EDA Method? Because our methodology is based on objective, international, advanced, and systemic criteria. Its conceptual foundation is the Hay Methodology, the most widely recognised model at international level.
Applying the EDA Method means bringing the same scientific rigour used by multinationals into your SME, while maintaining the agility, speed, and simplicity of a partner that supports you step by step and truly understands SMEs from the inside.
Want to know more?
The integrated team of Bacciardi Partners and Studio Macrelli e Bartolini Associati supports entrepreneurs and HR departments in the preventive analysis of pay systems and in the implementation of the EDA Method, with the aim of making corporate decisions technically defensible and sustainable over time.
Contact us to assess the compensation structure of your organisation.
By Antonella Lanzani – Head of Organization & People, Bacciardi Partners, and Hay Group certified professional