Practical governance considerations for mobility-related benefits and pay elements under Directive (EU) 2023/970

Who this is for

This paper is written for organizations that have employees working in the EU under any type of mobility arrangement, including:

• International assignments
• Local-plus arrangements
• Cross-border transfers and permanent relocations
• Cross-border commuters and rotational patterns (where applicable)

It is especially relevant for Mobility leaders, Total Rewards/Compensation teams, HR Operations, Payroll/HRIS, Tax, and Employee Relations professionals who must align on how mobility inputs feed broader pay transparency and pay equity processes.

What this paper is and is not

This is: a practical framework for making mobility outcomes explainable and defensible under a pay transparency lens, with focus on worker groupings, valuation consistency, and exception discipline.

This is not: a country-by country legal interpretation guide. Member state implementation and enforcement details will vary. The objective here is to define the governance foundations that remain relevant across jurisdictions and will support compliance execution as national rules mature.

Executive Summary

The EU Pay Transparency Directive will require many employers to explain, and in some cases remedy, pay differences between groups of workers performing the same work or work of equal value. For global mobility programs, the central challenge is that mobility arrangements often include non-base elements, allowances and benefits-in-kind, that can materially increase total remuneration compared to locally employed peers. Where these elements are included in reporting and assessment, mobility populations can materially affect pay outcomes. Many organizations are not yet set up to explain those outcomes consistently.

The highest-risk issues are rarely the existence of assignment support itself. The exposure shows up in three places: (1) worker groupings and comparability, especially where mobility types blur categories (local-plus, transfers, hybrid arrangements); (2) valuation consistency, including how mobility elements are measured and treated over time; and (3) exception governance, where individualized deals and undocumented deviations create outcomes that are difficult to justify under scrutiny.

This paper lays out a practical governance model to make mobility outcomes explainable and defensible under pay transparency.

• Establish clear population definitions,
• Align mobility categories to the organization’s broader pay transparency method,
• Apply a consistent approach to valuing mobility elements, and
• Implement controlled exception processes with ownership and documentation standards.