HR and future of work · Industry brief

Pay transparency regulations are advancing across multiple EU member states following implementation of the EU Pay Transparency Directive, with recent legislative and policy developments in Spain, Portugal, Finland, the Czech Republic, Greece and Bulgaria. The EU Platform Work Directive on algorithmic management of workers approaches its December 2026 implementation deadline, spurring draft legislation and consultations across Europe including the Czech Republic, Denmark, the Netherlands, Poland, Slovakia, Sweden and Switzerland, with developments also emerging in Australia and Hong Kong. Additional employment law developments include a significant German proposal to increase employer flexibility in terminating high-earning employees, ongoing board diversity initiatives across Austria, France and Poland aligned with the EU Women on Boards Directive, and strengthened collective bargaining and supply chain due diligence requirements globally.

The Central Bank of the UAE issued Circular No. 5/2026 on March 13, 2026, establishing a new Remuneration Regulation for banks and insurance companies effective April 14, 2026. The regulation fundamentally reframes remuneration as a governance and risk management issue rather than a purely HR function, requiring Board-approved frameworks that align compensation with strategic objectives and risk appetite. Key provisions include mandatory identification of Material Risk Takers whose activities significantly affect institutional risk, deferral requirements of at least 40% of variable remuneration over three years for Material Risk Takers and 60% over five years for Senior Material Risk Takers, restrictions on guaranteed bonuses outside the first year of employment, and enhanced disclosure obligations to both the CBUAE and the public. Financial institutions have 15 months from the effective date to implement compliance, with existing remuneration frameworks to be assessed within 180 days. The regulation requires coordination across legal, HR, risk, and compliance functions to align employment contracts and incentive arrangements with the new governance requirements.

On September 9, 2026, New York Governor Kathy Hochul signed Senate Bill S3460, amending the New York Labor Law to grant current and former employees access to their personnel records effective November 8, 2026. The law defines personnel records broadly to include employment application materials, performance evaluations, compensation information, and job descriptions. Employers must provide access within five business days at no cost, notify employees within ten days of placing negative information in their records, and allow employees to submit written rebuttals if they dispute record contents. Employers face fines of $500 to $2,500 for violations, enforced by the New York Attorney General, and are prohibited from retaliating against employees exercising their rights under the law. The regulation requires employers to update policies, establish request protocols, and train HR and management personnel on compliance requirements.