Moving Toward Trusted Transparency

Moving Toward Trusted Transparency
September 29, 2026 7 mins

Moving Toward Trusted Transparency

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Pay transparency is expanding, and employers need more than disclosure. Building trusted transparency requires defensible pay decisions, clear and consistent governance, and manager readiness.

Key Takeaways
  1. Pay transparency efforts are moving toward defensibility, requiring employers to explain how pay decisions are made in a clear way.
  2. Manager readiness is a risk. Training, consistent messaging and escalation paths are critical to building employee trust.
  3. Having the right data, governance and decision-support tools can help move employers beyond compliance to trusted transparency.

As pay transparency continues to evolve, employers are shifting focus. Companies are thinking beyond compliance and disclosure, and more about the defensibility of pay policies. However, changing regulatory environments across different geographies make the process tricky. This has led many companies to reassess the foundational aspects of pay transparency as they wait for clarity. Aon’s recent pulse survey on pay transparency revealed that approximately nine in 10 employers have taken at least one action to support pay transparency, but only about one in 10 said that transparency is fully embedded. There is still much work to be done.

The next phase of pay transparency will require managers to explain compensation in a clear and sustainable way. The challenge is whether organizations can defend their pay decisions to both regulators and employees alike. Only then will they achieve trusted transparency.

What is Trusted Transparency?

Disclosure is the outcome, but trust is the objective. Organizations that can consistently explain and defend pay decisions will be better positioned to earn employee confidence and manage regulatory complexity.

The Risk of Incomplete Transparency

Many organizations report confidence in their ability to explain pay decisions, with 44% saying they have high confidence.1 However, 80% of respondents say they have not tested this capability. This gap should be viewed as a significant risk, as many employers may be conflating activity with readiness.

Part of that risk comes from the varying scope of pay transparency in different places. Organizations are balancing growing regulatory complexity with the need for global consistency. In the U.S., pay transparency regulation is largely about putting reasonable salary ranges in job advertisements. In the EU, country-specific pay transparency regulation goes beyond base salary to consider total pay, including cash and non-cash programs like benefits and retirement. This heightens the need for organizations to clearly communicate the definition of pay and be prepared to explain and defend individual employee positioning.

11%

of respondents have fully implemented their pay transparency initiatives.

Source: 2026 Aon Pay Transparency Pulse Survey 2

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We need to get to a place where if we ask five different people within an organization how their pay is determined, we get a consistent answer. It’s about predictability and clarity. If the process is predictable and clear, it’s more likely that the outcomes will be aligned to what we expect.

Anthony Poole
Partner & Industry Sector Leader, Human Capital, Europe, the Middle East and Africa

Trusted transparency requires evidence-ready data, documented decision logic, audit trails and challenge-response processes. It also takes consistency, both in communications and actions. It’s best practice to use a global framework with meaningful local flexibility rather than country-by-country compliance. In other words, building a system of transparent, defensible pay based on objective criteria will make it easier to adapt to any local law or regulation. Without considering these important factors, employers risk not only incomplete regulatory compliance, but poor morale and a loss of employee trust.

Managers are Key, and Many Aren’t Ready

The most significant identified risk in Aon’s pulse survey is manager readiness. In fact, 43% name it as the largest unresolved risk. Training managers to communicate effectively and consistently on pay will be a critical task. Transparency succeeds or fails in conversations between managers and employees. While managers aren’t likely to become compensation experts, they require basic skills to have pay conversations that instill confidence. Clear guidance on what to say, how to convey simple messages and well-defined escalation procedures will help managers successfully navigate these conversations.

For example, a manager should be able to provide context on why an employee is positioned at a certain point within a pay range, using factors such as role level, experience, skills and performance without overpromising a specific outcome. They also need practical language for more difficult moments, such as when an employee sees a posted salary range and questions why their pay sits below the midpoint. In those cases, managers should be prepared to explain the process, acknowledge the concern and know when to involve in HR. A lack of consistent communication can create confusion, lessen trust and lower employee morale and engagement.

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Pay conversations can be challenging. Helping employees understand how pay is set, and how related decisions are made, provides a foundation to facilitate meaningful discussions. A transparent process and clear communications build trust.

Steve Guyer
Partner, Head of Rewards and Workforce Advisory, North America

5 Steps to Build Trusted Transparency

Here are five ways for employers to accomplish effective pay transparency that also builds trust:

  • 01
    Build Clear Job Architecture

    Create a consistent framework so that roles, levels and career paths are clearly defined and categories of worker can be easily identified.

  • 02
    Define Pay Decision Logic

    Document how decisions are made, including factors used to create initial salary ranges, increases and incentive pay. The goal is to make these decisions explainable and consistent.

  • 04
    Protect Privacy

    Use clear protocols to protect individual employees’ private data for what to disclose and when. Balancing transparency with privacy can be tricky. Guidelines for who can access data is also part of good governance.

  • 05
    Focus on Education and Communication

    Equip managers with the tools and resources needed to have continuous conversations about pay. Escalation paths are just as important as education on consistent communications.

Turning Compliance Readiness into Strategic Advantage

Many employers have slowed their efforts on transparency to wait for more complete regulatory guidance. But staying ahead of the curve to build systems that define job architecture and explain pay in a sustainable way will help companies adapt to country-specific requirements. It’s those that adhere only to the minimum standards that may struggle with the patchwork of shifting regulations.

“The ones that are behind can hopefully learn from the first wave of companies that have been successful,” adds Steve Guyer, Partner and Head of Rewards and Workforce Advisory. “The resulting momentum for building defensible pay systems should create a feedback loop that helps employers bring transparency into focus.”

The path forward for pay transparency will be defined by explainability, governance, manager capability and readiness that can be proven.

Having that foundation will not only make compliance easier, but it will build trust throughout the organization that can be turned into strategic advantage. Learn more about how Aon is helping organizations build trusted pay transparency.

Aon's Thought Leaders

Anthony Poole
Partner & Industry Sector Leader, Human Capital, Europe, the Middle East and Africa

Steve Guyer
Partner, Head of Rewards and Workforce Advisory, North America

1 Unless otherwise noted, all statistics are from the 2026 Aon Pay Transparency Pulse Surveys.

General Disclaimer

This document is not intended to address any specific situation or to provide legal, regulatory, financial, or other advice. While care has been taken in the production of this document, Aon does not warrant, represent or guarantee the accuracy, adequacy, completeness or fitness for any purpose of the document or any part of it and can accept no liability for any loss incurred in any way by any person who may rely on it. Any recipient shall be responsible for the use to which it puts this document. This document has been compiled using information available to us up to its date of publication and is subject to any qualifications made in the document.

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