USA 
United Kingdom
Pay transparency is fast approaching in the EU, with knock-on effects for the US, and HR leaders are being warned to act now.
Kent Hviid Frederiksen, Vice President, Head of Rewards at the Lego Group, says equal pay is only as strong as the framework that supports it. With the EU Pay Directive coming into force in June 2026, businesses will need to ensure their job architecture and salary structures are watertight, transparent, and consistent.
“Relating this to pay transparency, if you don’t have an architecture in place today, you need to get moving,” he says. “That’s how important it is.”
Frederiksen will be speaking at next month's UNLEASH World 2025, where he will share insights on how HR leaders should prepare for the change in legislation.
Job architecture and fair pay
For the Lego Group, job architecture is seen as the framework around which everything else is built, said Frederiksen. Once that framework is “clear, fair and in place,” businesses will be in a better position to create fairness while implementing strategic workforce planning.
“It [job architecture] is vital for pay transparency so that you objectively can show criteria for how you do fair pay. Without it, it’s going to be arbitrary and inconsistent,” he said.
Frederiksen added that job architecture and salary banding are connected in a similar way that job levels indicate the median/salary range and guide organizations on how to set salaries.
When the EU Pay Transparency Directive takes effect, he anticipates HR leaders will see a “big surge of people asking for all kinds of details.” Businesses will be mandated to tell employees they have the right to ask, which he says will increase the number of questions raised.
For over six years, equal pay scans, payments and corrections have been in place at the Lego Group. “There are going to be pockets that we have not foreseen, or could not do the math on as a desktop exercise. So, what we’re doing right now is hopefully more of a dry run before we go live,” he adds.
Educating leaders for transparency
Frederiksen said educating leaders, partners, and recruiters is crucial. “Leaders are going to have to proactively tell some of their team why they’re low comparatively to others and ideally with objective criteria. The main objectives for businesses should therefore be to avoid differentiating pay unevenly or unfairly.”
He says fair pay is “the right thing to do,” adding: “If you can’t objectively justify it, you will have issues. You really need a solid structure.”
As chairman of the Global Works Council, Frederiksen also engages with works councils worldwide to ensure alignment on reporting requirements.
“I remain slightly concerned but well prepared as we have a serious and long journey ahead.”
