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The Next Move

The Salary Conversation Should Not Be the Last One

EU rules now set a framework for earlier pay information, while Malta has adopted national regulations. But a salary range is not automatically total compensation, national implementation differs, and transparency does not guarantee an offer or outcome.

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Editorial illustration / The Next MoveNot a photograph of a reported event.

“We have decided to move forward with another candidate.” Imagine hearing it after three interviews, a presentation and several weeks of trying to work out whether the move would make financial sense. The rejection may be ordinary; the avoidable part is discovering only then that the budget was never close to workable.

The budget belongs near the beginning

The practical answer is simple: ask for the budget, base-pay range and compensation structure before you invest materially in the process. You do not need to make compensation the only subject of the first exchange. But before an interview becomes a sequence, establish the employing location, the expected level, the base range and whether the employer is discussing guaranteed pay, variable pay or both. Under the EU pay-transparency framework, applicants are entitled to initial pay or a pay range in time for informed negotiation, including in a vacancy notice, before an interview or otherwise, as explained in the EU directive.

That is an information right, not a promise that you will receive the top of the range, a particular bonus or an offer at all. It gives you a better decision point. If the range is plainly below what would make a move viable, you can decline early. If it is plausible, you can spend time learning whether the role, authority and risk justify continuing.

What the EU framework changes—and what it does not

Directive (EU) 2023/970 required Member States to transpose its pay-transparency rules by 7 June 2026. That date is a transposition deadline, not a claim that every national law began operating in the same way on that day. National legislation, commencement provisions, enforcement practice and remedies still need to be checked country by country.

At directive level, applicants must receive information about the initial pay or its range, based on objective and gender-neutral criteria, early enough to support informed negotiation. Employers may not ask applicants about pay history during current or previous employment. The precise process for making a request, challenging a breach or obtaining a remedy depends on the national implementation.

Malta is a useful example of why the distinction matters. Its June 2026 Equal Pay (Transparency and Reporting) Regulations cover public and private employers, provide applicants with access to initial pay or a pay range and prohibit requests for salary history. Malta’s government also says the regulations came into force in June. The accompanying explanatory notes warn that they are not an exhaustive or authoritative interpretation, so a detailed question about remedies, reporting schedules or penalties should be taken to the operative legislation or a qualified adviser.

A range is not the whole package

The first question is what number you are actually being shown. Base salary, target bonus, commission, equity, pension, allowances, insurance and other benefits should not be silently collapsed into one attractive total. Ask for each component, whether it is guaranteed or conditional, and what assumptions sit behind it.

The EU directive uses a broad concept of pay for equal-pay and reporting purposes. It includes complementary or variable components such as bonuses, overtime compensation, allowances and occupational pensions. That does not establish a single EU-wide rule requiring every advertisement to place the full value of equity, benefits and bonuses inside the published salary range.

The US comparisons show the difference. California requires covered employers to publish the salary or hourly pay scale, but bonuses, tips and other benefits do not have to be included in that pay scale. New York State likewise treats benefits, bonuses, stock and other compensation separately from the minimum and maximum rate of pay. Neither rule should be used to infer the law in Malta or another EU Member State.

A sensible question is: “Is this the base range, and what sits outside it?” Then ask whether the role has a target bonus, whether commission is capped, how equity is described, whether pension or insurance is employer-funded, and whether the package changes by employing country. You are not demanding a crystal ball. You are separating fixed money from contingent money before comparing offers.

When breadth becomes a practical problem

A broad range is not automatically deceptive. It may reflect different levels, scarce skills, genuine discretion or a role whose scope is still being finalised. The useful test is whether the employer can explain the range: what distinguishes the lower and upper ends, which level is being considered, and where a plausible offer would sit.

New York State guidance says a good-faith range should be one the employer legitimately believes it is willing to pay, and that a range so broad that an applicant cannot understand the legitimate range is not good faith. The state also rejects open-ended wording such as “and up”. That is a jurisdiction-specific rule and guidance, but it captures the practical issue: a range that contains every conceivable outcome may technically look informative while deciding very little.

Location makes the question sharper. For multiple locations, New York guidance calls for multiple ranges rather than one broad range covering different geographic regions. For a cross-border or remote role, ask which entity employs you, which location determines the budget and which country’s rules govern the recruitment process. Salary information can clarify a job decision; it cannot by itself prove that the job is approved, funded or available on the terms advertised.

What the evidence says about outcomes

Transparency changes information first. A 2025 NBER working paper on US state-level disclosure policies found a 30-percentage-point increase in the share of postings containing salary information and estimated wage increases of 1.3% to 3.6%, while finding no measured effects on employment, posting volume, pay dispersion or skill and education requirements. Those are policy-level estimates from a specific research design, not a promise to an individual applicant.

A separate 2025 Economics Letters study of nine US states estimated an insignificant 1% to 6% decline in job postings, with temporary and generally insignificant employment effects. The findings concern different data and methods from the NBER study; they should not be averaged into a single verdict about transparency.

The OECD’s 2026 synthesis cites field-experiment evidence involving about 2,500 job-seekers in which clearly stating the salary range and whether pay was negotiable increased women’s likelihood of negotiating. Negotiating more often is not the same as receiving a higher offer, and neither is a guarantee that one candidate will obtain the top of a range.

Nor does transparency arrive perfectly just because a rule exists. A New York Fed analysis of Lightcast postings in selected US jurisdictions estimated that approximately 24% of covered advertisements still omitted wage information in January 2025. That is not a national statistic and does not explain each omission, but it is a reminder to treat the published range as evidence to examine rather than as a complete description of the employer’s intentions.

If the number changes late

A changed range is not automatically misconduct. The company may have re-scoped the role, changed location, split one position into two levels or lost approval for part of the budget. But it is a material change in the decision you were being asked to make. Ask for the revised base range in writing, the reason for the change, the level now under consideration and a clear breakdown of variable compensation and benefits.

Then decide whether the new terms justify continuing. You can say that the revised range is outside your parameters, ask whether the scope can support the original level, or continue while treating the new figure as the actual budget rather than an opening bid. Keep the tone factual. A compensation conversation is not a test of loyalty, and a legal right to information does not require you to remain in a process that no longer makes economic sense.

The best timing is therefore neither “wait until the offer” nor “refuse every conversation without a perfect total-compensation spreadsheet”. Ask early enough to protect your time, then ask precisely enough to understand what the number means. The salary conversation should be one of the first serious conversations—not the last unpleasant surprise.

What to clarify before moving forward

QuestionWhy it mattersWhat to request
What is the base-pay range?It tells you whether the role is financially plausible before interviews.Minimum and maximum salary, currency and pay period.
What is variable?A target bonus or commission is not the same as guaranteed salary.Target, maximum, eligibility rules and recent payout practice, if available.
What is location-specific?The same title may carry different budgets in different countries or cities.The range for your employing entity and work location.
What happens if the range changes?A late change can make earlier conversations costly and misleading.The reason, revised range and whether level or scope has changed.
Go beyond the headline

The evidence.

Evidence cutoff: 2026-10-05. Later developments may change this picture.

  1. European Commission — EU action for equal pay
  2. EUR-Lex — Directive (EU) 2023/970
  3. Government of Malta — Government Gazette and Explanatory Notes
  4. Government of Malta — Ministry press release
  5. California Department of Industrial Relations — Labor Commissioner’s Office
  6. New York State Department of Labor — Pay Transparency Act FAQ
  7. National Bureau of Economic Research — Working Paper 34480
  8. Economics Letters — The effect of mandatory salary revelations on job postings
  9. OECD — Pay Transparency in Progress
  10. Federal Reserve Bank of New York — Pay transparency compliance analysis

What would change this story?

  • Check each relevant country’s final implementing law, commencement provisions and enforcement guidance rather than relying only on the 7 June 2026 EU deadline.
  • For Malta, verify the operative Legal Notice and any official guidance on remedies, reporting schedules and penalties.
  • Track whether later studies distinguish advertised base pay from accepted pay and total compensation.
  • Watch evidence on whether employers revise ranges during recruitment and how national authorities treat materially changed budgets.

Independent reporting and editorial analysis. Forecasts are not observed outcomes; career suggestions are not guarantees. Employment rights depend on jurisdiction.

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