EU DIRECTIVE 970/2023: TRANSFORMING COMPLIANCE INTO A CULTURE OF VALUE

The 7 June 2026 is not a deadline to be feared. It is the date by which Italian companies must have transposed the Directive (EU) 2023/970but it can become the moment when your organisation makes the most significant evolutionary leap in human capital management in recent years. We are not simply talking about adapting HR processes or publishing pay gap data: we are talking about redefining the way in which the value of work is recognised, measured and remunerated.

European legislation introduces stringent obligations, from the reversal of the burden of proof in case of litigation to reporting obligations for companies with more than 100 employees, but hides a rare opportunity: that of building truly fair, transparent and predictive professional systems. The question is no longer whether to comply, but how to do so in such a way that compliance generates sustainable value.

The risk of 'friendly fire': when compliance is not enough

Many organisations are approaching Directive 970/23 as a mere compliance exercise: they collect data, calculate medians, prepare reports. But there is an invisible risk that no software can mitigate: the comparison in management. A perfectly 'gender-neutral' position classification system can be thwarted by a single manager who assigns strategic projects in a discriminatory manner, or who excellently evaluates a resource for years without ever promoting it.

As emerges from our experience in the field, the real vulnerability lies not in formalised processes, but in the daily management practices. This is where the pay transparency game is played.

The Alveria Methodology: beyond compliance, towards transformation

That is why we have developed an integrated approach that articulates the adjustment pathway in three operational phasesdesigned to turn regulatory obligation into competitive advantage:

1. Organisational Assessment: building gender neutral foundations

The first step is not mathematical, but architectural. We analyse the existing professional structure for consistency with the principles of gender neutrality, distinguishing two scenarios:

• In the presence of classification systemsWe verify that the progression criteria do not contain historical bias or unintentional distortions;
• In the absence of structured systemsWe define a basic model for grouping company populations by the four normative criteria (skills, responsibility, commitment, working conditions), using objective and documentable rating scales.

This is where our Job Evaluation 970 Smart, a proprietary tool that allows positions to be classified through algorithmic and taxonomic logic, ensuring consistent and statistically validated clusters (with silhouette indices above 0.7).

2. Remuneration Assessment: the diagnosis that prevents litigation

We transfer to HR functions the methodology for conducting remuneration analyses in accordance with the Directivegoing beyond the simple calculation of the gender pay gap.

Our methodology includes:

• Disaggregated analysis by cluster of 'work of equal value', not just for single organisational positions (critical when a position is held by very few resources);
• Verification of deviations above 5%with documentation of objective justifications and assessment of methodological robustness;
• Indirect bias mappingfrom the distribution of part-time contracts to differentiated access to training and special projects.

This phase is crucial for managing thereversal of the burden of proofOnly rigorous and predictive documentation can protect the organisation in litigation, distinguishing between justifiable gaps (seniority, differentiated skills) and systemic disparities.

3. Reporting Dashboard: Transparency as an experience

The last phase is not technical, but communicative. We develop reporting tools that not only satisfy the supervisory authorities, but become internal dialogue tools. Our dashboards include perspective indicators, vertical mobility, access to talent programmes, participation in leadership courses, because we know that today's equal pay depends on yesterday's development choices.

The transposition of EU Directive 2023/970 is not a finishing line, but a starting point. Organisations who know how to interpret this regulation as an opportunity for systemic renewal, investing in transparent professional systems, reliable data and responsible leadership, will not only be compliant. They will be more attractive on the labour marketmore resilient to legal risks and, above all, more consistent with the values of fairness that more and more talent and stakeholders demand.

The date of 7 June 2026 is coming. The question is: do you simply want to get there, or do you want to use it to build the organisation of the future? Contact us to understand how to accompany your organisation on a structured, safe and value-oriented path beyond compliance.