In this Coffee Talk Special, Henrike von Platen speaks with Lea Lønsted, Head of Rewards Transformation at Danske Bank and a long-standing member of the FPI Screening Board, about a question that is often treated as technical, but is in fact foundational: what a pay structure is, what it must contain, and why it cannot be treated as a finished exercise under the EU Pay Transparency framework.
Lea defines pay structure as the framework an organization uses to set and manage pay. In her explanation, it rests on three connected elements: a clear job architecture with defined job families and levels, pay ranges that establish boundaries for roles, and objective, gender-neutral criteria that determine how people are positioned within that structure. These elements matter for consistency and fairness, but also for compliance. The discussion makes clear, however, that the presence of a structure does not by itself prove equitable pay. A company may have job architecture and pay ranges in place and still fail to apply them fairly in practice. For that reason, objective and gender-neutral criteria must not only exist on paper; they must be applied consistently and be supported by analysis that shows whether comparable roles are in fact being treated according to the same rules.
The conversation then turns to the question of why pay structures need to be revisited. Lea notes that many organizations developed their structures some time ago and that those structures may have made sense at the time. The regulatory context has since changed. The EU Pay Transparency Directive introduces requirements that make a renewed review necessary, including the need to embed gender-neutral criteria explicitly, to provide pay range information to job applicants, and to ensure that employees can understand how their pay is determined and how it relates to similar roles. The discussion also refers to the obligation to disclose gender pay gap information and, where relevant thresholds are exceeded at worker-category level, to show remediation efforts. In this context, revisiting the pay structure is not presented as optional maintenance, but as a necessary part of governance and defensibility. Henrike adds a practical point: organizations are not static, and the movement of people into, within, and out of roles means that structures must be checked against current reality on an ongoing basis.
A further focus of the exchange is communication. Lea describes pay structure as a change topic that must be communicated in a way that is understandable beyond the compensation function. This requires organizations to make criteria and ranges accessible, explain how they apply, and avoid specialist language that limits understanding. The conversation distinguishes clearly between transparency and full disclosure: the directive does not require broad disclosure of individual pay, but it does require pay range information to be available to candidates, and it raises the broader question of how organizations want to handle comparable access to information for existing employees. Lea also underlines that communication cannot remain an HR-only responsibility. Leaders need to be equipped to explain the structure and to handle difficult conversations in a clear and consistent way. The overall position of the exchange is that a pay structure only becomes effective when it is not only formally defined, but also understandable, explainable, and usable in practice.