In this Human Capital Insight episode of the On Aon podcast, Aon leaders discuss how organizations are taking pay transparency from a regulatory requirement to a leadership priority. Drawing on findings from Aon's 2026 Pay Transparency Pulse 2 Study, they explore why trusted transparency depends on strong data foundations, clear governance and confident decision-making. The conversation examines how leaders can strengthen employee trust, equip managers for more effective conversations and create a scalable approach that supports workforce confidence and long-term growth.
Key Takeaways:
Experts in this episode:
Key Moments:
(3:20) How the EU Pay Transparency Directive is accelerating action globally and why leaders need a framework that balances consistency with flexibility.
(7:25) Why confidence should be tested through execution, and how organizations can evaluate whether their pay transparency programs are delivering as intended.
(21:35) The priorities leaders should focus on now, from strengthening data foundations and governance to improving the employee experience.
Soundbites:
Laura Wanlass:
“It's clear from the second pulse survey that organizations have moved beyond debating whether to act. And the question really is now whether their data, their governance, managers, and decision processes can support transparency consistently and credibly.”
Steve Guyer:
“I think at the end of the day, disclosure is the outcome, not the starting point. Trusted transparency rests on strong foundations, consistent decisions, and the evidence that the process works.”
Anthony Poole:
“When we talk about our phrase of trusted transparency, employees have to trust both the data and the process behind paying decisions. So the organizations need to build trust when they can provide consistent explanations supported by reliable data, good governance and manager capability.”
Key Resources:
2026 Pay Transparency Pulse 2 Study
Steve Guyer
I think at the end of the day, disclosure is the outcome, not the starting point. Trusted transparency rests on strong foundations, consistent decisions, and the evidence that the process works.
Intro:
Hello and welcome to this week’s episode of On Aon. Pay transparency is moving from policy to practice—and organizations need to know whether their data, processes and managers are ready. In this episode, Laura Wanlass speaks with Steve Guyer and Anthony Poole about the findings of Aon’s latest Pulse Survey and what leaders should do next.
Laura Wanlass
Hello and welcome to On Aon. I'm Laura Wanlass, and today we are looking at what organizations have learned as pay transparency moves from a policy and disclosure focus into a day-to-day operating reality.
Earlier this year, Aon's first pay transparency pulse survey showed widespread activity, but also clear readiness gaps. Our second pulse survey, conducted after the EU directive came into effect, asks a different question. Are organizations now able to explain, support, and consistently govern the pay decisions behind greater transparency?
So joining me today are Steve Guyer, Head of Rewards and Workforce Advisory for North America, and Anthony Poole, a partner in our global human capital consulting practice. Together, we will discuss what changed between the two pulse surveys, including why corporate confidence can be misleading, why connected workforce data across numerous data sets and channels matters and what leaders should prioritize right now. So, Steve, let's start with the headline. What did Pulse Two tell you that Pulse One could not?
Steve Guyer
Pulse Survey One focused on the question: Have you started on the road to transparency? It established that action to pay transparency was widespread, with about 91% of respondents indicating they had taken at least one action toward transparency. It also showed that respondents were in various states of foundational readiness, anywhere from three-quarters of organizations working on job architecture to others working on initial pay equity analysis, publishing pay ranges, formalizing manager training, and redesigning pay structures, all at varying rates. They weren't all consistent in how they were, what activities they were working on, or which activities they were working on in parallel.
Pulse Two moves from the question, “Have you started to can the operating model work at scale and under pressure?” So, at the extremes we have 11% of survey respondents that say pay transparencies are fully implemented and embedded, while 7% have yet to take any action; at least 82% in the middle that are still working on foundational activities. Tying those activities together or largely at complete stages.
So there's a lot of activities still in play. But Laura, to answer your question, Pulse One told us organizations were moving. It was a great thing. PulseTwo tells us whether that movement has produced a whole capability to respond to requests, to be compliant, and to be in a good position.
Laura Wanlass
Great. So a quick follow-up before we go to the next main question on the survey, you know, building off what Steve just said here, if listeners should not read these as point-to-point trend numbers, what's the right way to interpret the two studies in conjunction together?
Anthony Poole
Maybe I'll jump in on that one Laura. I think fundamentally this this piece around transparency and this visibility just gives employees more information. So when we start talking about trust, trust really depends on whether the organization can and has explained that information clearly, consistently and credibly.
Because we need people to buy into it. It means that we have people saying the same thing in the face of consistent questions. We have actions that are aligned with intentions. And people have a real sense of engagement with what they're being told.
Laura Wanlass
That's helpful. Okay, so let's move on to the next phase of the poll survey. And this one's for you, Anthony. What did the EU directive milestone really change?
Anthony Poole
Yeah, it's a good question, Laura. It's one that comes up quite a lot . We would always say pay transparency has been a global theme. It's not just been about the EU directive, but the EU directive has been a catalyst to so much of why this is high on the agenda. The EU directive requires transparency, yes, but we've seen that in other locations. There's also a need under the EU requirements to more fully understand the gaps that we have in an organization and to actively address them and be clear about how we're doing that.
I'd also say that the level of transparency is greater and more specific in the EU directive as well. So that will naturally drive more engagement as people have more information to work with and more questions probably around that information. If I think about the study, among EU applicable respondents, about 35% reported active or accelerated action, while 65% remain in a selective, delayed or no action mode.
I think the local uncertainty of transposition has shaped a lot of that pace and prioritization and created a lot of uncertainty as well, which is really challenging for us as organizations across different locations, but also for us as consultants in helping people to solve those questions.
When we think about what does global consistency mean, things like job architecture and job evaluation, thinking about our category of workers, that is something that organizations would attempt to have globally consistent. Robustness around data. As we know, the definition of pay under the EU directive is very broad. It doesn't just include salaries and incentives. It includes, under the wording of the directive, everything the employee receives in cash or in kind in respect of their employment.
The way we understand and address our pay gaps and how we talk about those, I think, is something that increasingly we would want to look at globally. There might be some nuance to that. And certainly, some of the things around governance and audit and the accountabilities that sit with different people.
The local piece I think becomes very much about education and communication, to make sure that we are talking in the right way in respect of local requirements and relative to what we are sharing. So that practical response I think is a globally coherent framework with meaningful local flexibility.
Laura Wanlass
Interesting. So a quick follow-up of what you just said, Anthony, when you think about all of the bifurcated regulatory regimes between local versus global, what should a big multinational organization decide centrally?
Anthony Poole
So I think some of the things I just described were around the job architecture, et cetera, is certainly something you would want to try and apply globally, particularly as we start to think broader around career frameworks and skills and how we want to be enabling talent within an organization. But if I take a couple of specifics, I think maybe a common mistake is making pay transparency solely about salary ranges.
As I've said, the data is broader than that, the requirements are broader than that, but we can start to connect this transparency into a real positive around things like career growth, internal mobility, performance distribution, and overall employee understanding and alignment with what we're trying to deliver as an organization.
When we talk about our phrase of trusted transparency, employees have to trust both the data and the process behind paying decisions. So the organizations need to build trust when they can provide consistent explanations supported by reliable data, good governance and manager capability. And I think underpinning that, the consistency that we can drive across locations will be a real value.
Laura Wanlass
Yeah, that makes sense. You know, when I reflect on what you just said, given the local market nuance and the need for the bifurcated approaches to meet local requirements, it would seem interconnectivity across an organization remains incredibly important as companies continue to move forward in this pay transparency journey. And it would seem that companies have gotten to the point that they might be getting more confident in this coordination. But this leads me to a question for Steve. Why might confidence be ahead of the proof at this point?
Steve Guyer
It's a great question. I mean, confidence reflects what leaders believe the process should do. Proof really comes in from seeing whether it works when a difficult question arrives. So we can be confident that we've set up a process, we've set up some type of order to how things should happen, but actually truly understanding what that is, what it means, and to be able to speak with confidence is truly where the rubber meets the road.
Forty-four percent of our respondents in the second pulse survey report high confidence in explaining a pay decision, but only 20% say that capability has been tested and proven. So they feel confident that they've done the training, they've provided the information, but we have yet to know whether in the end, when the questions do come up, whether we can answer them with significant confidence. Well, 35 % of the participants have partially tested it, which leaves almost half, about 45 % of respondents that have not tested that capability. That is a gap right now.
When we think about testing, when say testing, it's examining whether the organization can reconstruct the decision, validate data, job context, document exceptions, coordinate handoffs with HR and legal, as well as support the manager escalation. Because in not in all cases, managers won't be able to answer all questions. We know that. So giving them the backstop, as I call it, or that escalation point to say, we'll get right back to you. I'm going to go speak to so and so and we'll get back to you with the appropriate answer. So having confidence in the process is important that we have the process but truly proving that at the end of the day, we can answer the questions that are going to arise or we have that escalation point to make sure that the employees feel like their questions are being responded to.
Laura Wanlass
Yeah, that makes sense. So Steve, I want to build a little bit more off this notion of trust for a second. When you think about trusted transparency, how is it dependent on connected workforce data? Like how is seeing the bigger picture important to this idea of trust?
Steve Guyer
The data is critical. Connecting all this information, especially with the EU pay directive, you're connecting career and rewards and all different types of rewards together to create outcomes for reporting and for compliance reasons. But pay transparency depends on reliable connection between your HRIS data, so your people data, your job data, job architecture, your internal ranges, external benchmarks, and your performance information. So making sure that programs are being applied equitably, but the information is being pulled together.
What you want to avoid is fragmented or inconsistent inputs. They can erode trust because the organization may not align or the explanation may not align from one system or audience or decision point to another. So that can be problematic if you don't have that consistency of messaging and story and folks can see how the data flows and fits together.
The other piece is the employee experience. It's another part of the equation as employees encounter transparency through communications with one another, manager conversations, and just general understanding of the organization's programs.
To be clear, more connected data does not mean disclosing more information. You still have governance, privacy considerations, access rights, and disclosure guidelines to determine what's shared. The goal is not to disclose every available data point, it's to connect the right information. So the organization can provide a relevant, consistent, and defensible explanation to employees.
Laura Wanlass
Yeah, that makes a lot of sense. It's not just about the multitude of data. It's figuring out the insights from the data, being consistent about what you're required to disclose versus how you get the most out of the data and get the right conclusions. To your point, making sure that it's defensible. Okay, so I do have a follow up for you, Steve. What specific information do you think needs to connect? You know, you just made the point about data needing to connect.
Steve Guyer
What I love about this honestly is when we think about the EU pay directive, as Anthony said earlier, it really does start to focus. It's more focused on career and rewards and bringing this all together. It's not just on rewards. So when we think about the connected information, it's everything from your rewards and career philosophies and strategies to your organization of jobs, your articulated job architecture, which establishes the responsibilities, expectations, and skill requirements at each career level within the organization.
How pay eligibility and opportunities align with that career advancement. And ultimately the integration of pay and performance. And then that connection, as I just mentioned, of all those pieces, the storage and connection of your pay and rewards data to get to what pay means within your respective organization, your respective geography. So ultimately, it's understanding how all this is connected to provide employees with equitable career and rewards opportunities to attract and retain the best talent or keep them motivated. So what I said, when we think about connected information, the reason I say I really think it's important, I love this piece because it truly is a foundation for connecting not just the pay side of the house, which gets a lot of focus, but the career connectivity as you advance, how your pay potential can advance and ultimately how we want to continue to have equitable practices across the organizations so that we're giving everyone the same opportunity and this the same experience or a similar experience within the organization.
Again, I think that'll go a long way to attracting and mainly retaining the talent we do have. If they feel connected, they feel like they have equal understanding of the programs and how it all comes together.
Laura Wanlass
Well, that's actually really helpful, Steve. You mentioned the topic of managers as a potential point of connection that could break down for obvious reasons, right? The complexity of everything that's come into play and what we're asking managers to do. So, Anthony, why do we think the low manager readiness appears to be consistent across both the first pulse survey and this one?
Anthony Poole
Yeah, thanks, Laura. This was a result coming out of the study actually that we were delighted to see because it has been our experience of working with clients. There's a lot of focus on manager readiness just now and Pulse One found 51 % rated manager preparedness low or not started, with only 7 % rating it high or fully operationalized. Roll forward to Pulse Two, and still we saw manager readiness as the largest unresolved capability gap of 43 %, more than three times the next largest individual gap.
The second one being job architecture or roll cap clarity at 13%. I think it's partly related to do we have all the information, do we have all the structures in place that we want our managers to ultimately communicate? Because we've got to have those structures in place before we can roll forward into thinking about how we want to talk about them. So that I think has been a challenge. But also, how do we then think about communicating that to managers? Do we have working groups? Do we have FAQs in place? We would probably say that training alone is not enough. We need to have a clear pay philosophy in place. We need to have decision guides. We need to have practical scenarios and escalation paths. So organizations need to have taken time to train managers in a practical environment; put the questions to them that they're likely to have to face.
One of the things we would say is line managers really are where the policy becomes the employee experience. They are going to be first people to receive the questions and so we want them to make sure they're answering the right questions, they're answering them consistently. We want to be clear on what we want them to be saying in response to those questions, but also which questions we want them to be answering, because some of those questions maybe they do need to sit in a different place. But we just have to be clear on our strategy for what is for line managers versus what is for the HRT.
Laura Wanlass
I mean, that makes a lot of sense. And I think we've had a lot of discussion and focus on managers here because they're on the front lines and maybe have the most access to employees. But let's transition a little bit for both of you to go beyond managers and think about that next level above the managers. You know, what should the leaders above that front line be doing right now in terms of pay transparency? And let's start with you, Steve, and then maybe Anthony, you can jump in after.
Steve Guyer
Yeah, I think like we've been talking about, I think number one is really assessing the maturity of readiness, right? Identifying whether the program is simply active or genuinely embedded. Now, is our expectation at this point, especially with the EU pay directive, that everything's ticked and tied and embedded? No, but we should understand where we are in that continuum so that we continue to focus our efforts, our resources, our funds to getting us to being truly ready and have an embedded program.
Think that's the first one. The second is we've been talking about this testing explainability. So utilizing realistic requests cases to find the breaks in our process and in our work thus far. So testing it with taking some of those challenging questions maybe received already from employees in countries in the EU in perspective in particular where the law has been regulations have been transposed or just really trying to figure out what are some of the most challenging questions that might arise.
So thinking outside the box and testing that explainability at that local level. And I think the third piece that I would say is really continuing to connect and strengthen all the data we've been talking about from the employee and job data, the HRS data, your architecture, your ranges, the performance information, the decision guidelines and processes, just testing and continuing to connect and strengthen that. Again we know most organizations won't be perfect out of the gate. It will be an evolutionary process of which you'll want to continue as a leader to keep a focus on, to keep an eye on, and again, invest the time, resources, and funding as necessary in the right spots to make sure that you continue to strengthen your position, to not only be compliant, but to create that better employee experience.
Anthony Poole
And maybe to follow on from that, Laura, I think again as from a leader's perspective, all of those things Steve talks about, but within each of those, it's always about as leaders questioning and challenging the validity of what we're saying and what we're doing. Right? We say this is our method, this is our approach, this is our guidelines, but does it really stand up to how we behave? Because in a world of transparency, that's where the cracks will come if there isn't that kind of alignment. So how we're using information. I talked about myth busting earlier driving consistency is so important.
Also, I think moving on to some of the broader breadth of this and the impact on the organization going forwards is very much about enabling the employee experience, right? So ensuring that our managers do have the training. That again, we validated that it covers the right topics. We're going through scenarios, we're fulfilling it in a total rewards context, if that's our perspective and how we talk about that. We've got our talking points right and again this word consistent we have FAQs, we've got escalation routes, so that the communications and the conversations have consistent definitions and decision logic.
If we're not consistent, then that will come out over time. I think also the governance of data and the disclosure globally is going to be very important. We've got to again be establishing common definitions and data standards and access rights. Controls and principles are so important to make sure that we can have this, going back to our earlier point, this global consistency where appropriate, but the meaningful local civility, where either culturally or from a regulatory standpoint, because of local transposition, the requirements feel a little bit different. I think repeatable review processes and again consistency and how we're going about this from a leadership standpoint are all so important and so valid to making sure we do it successfully.
Steve Guyer
If I could add one more, and you know we've had a lot of focus on the EU pay transparency directive right now. But when we think about global pay transparency, it's something different in North America as it is in Europe and other parts of the world. I think as a leader as well, to truly understand what transparency is from a compliance perspective in a location, but also thinking about what is our common thread, as we talked about earlier on in this conversation, from a philosophical and strategic perspective, what do we think about globally versus what do we want to do locally.
Just because the regulations say we have to disclose X, Y, and Z doesn't mean we can also talk about A, B, and C as an organization, as to what we believe in. And you can go beyond that. And I think as a leader, we want to continue to stretch our thinking on what needs to be more, what should be more globally focused as opposed to just locally compliant.
Laura Wanlass
Yeah, that makes sense. So if when I listen to both of you speak on what's changed from Pulse One to Pulse Two, I hear a couple things. I hear locality matters, connectivity matters, room for improvement on manager readiness, and that leadership focus on this topic should be a strategic one, not just an operational one. That's really the core of everything you've said. And if our listeners are going to remember only one thing, I want to ask both you, Steve, and Anthony.
What should that one thing be? Starting with Steve.
Steve Guyer
I think at the end of the day, disclosure is the outcome, not the starting point. Trusted transparency rests on strong foundations, consistent decisions, and the evidence that the process works.
Laura Wanlass
Great. Anthony?
Anthony Poole
I think more than anything, it's probably not to confuse our confidence in the great work we've done with the proof that it works. Right. So this idea of testing how our organization would explain, for example, a difficult pay decision before that process gets tested on us is going to be important. So we know it works, not just we're confident in the background we put in.
Laura Wanlass
Great. Okay. So I think that was really helpful context and great insights to leave our listeners with. And it's pretty clear that pay transparency has entered a new phase. It's clear from the second poll survey that organizations have moved beyond debating whether to act. And the question really is now whether their data, their governance, managers, and decision processes can support transparency consistently and credibly. So thank you both Steve and Anthony for joining us. And thank you everybody on here for listening to On Aon.
You can find the Pay Transparency Pulse Survey Two report and related resources in the show notes.
Outro
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