A recruiter opens a requisition template and fills in a salary range, because under the Pay Transparency Directive the range goes to candidates before interview and questions about salary history stop [9]. The range being in the advert is the easy part. The part no system currently handles is showing, eight months later, which range a specific named candidate saw on the day they applied, and who changed it after.
That is the shape of all four dates. According to TNW, the design principle running through them is simple: proving misclassification, unequal pay or an unfair algorithmic decision used to fall to the worker, and now it increasingly falls to the company [2]. Twenty-three of the 27 member states missed the June 7 pay transparency deadline; counting Greece, which finalised shortly afterwards, 22 still have nothing in force [1]. Italy, Slovakia, Lithuania and Malta made it [4]. Germany, Spain and Sweden sit somewhere between partial implementation and no published draft, with Sweden paused entirely while it seeks renegotiation [5]. France, the Netherlands and Denmark are aiming at January 1, 2027 [6].
Teams may treat the gap as bought time, but what it actually buys is a period in which one job advert is legal in one member state and non-compliant in another, with the employer's own location deciding which [11], while the reporting clock runs anyway. First gender pay gap reports are due in June 2027 [10], and the comparator data those reports rest on is being created now, in applicant tracking systems and payroll exports that were built to answer this quarter's questions.
Article 50 of the AI Act became applicable on August 2, carrying penalties up to 15 million euro or 3% of worldwide annual turnover [12]. Above roughly 500 million euro of turnover, the percentage is the larger number [2]. It applies whether or not the system is high risk, which pulls in candidate chatbots and AI-drafted recruitment mail [13]. The retention question there is per session, not per policy: what disclosure did this candidate see, and can the company reproduce it. The heavier high-risk HR obligations moved to December 2, 2027 under the AI Omnibus [14], exactly one year after the Platform Work Directive transposition date [3]. TNW reports that plenty of companies built governance timelines around the old August 2026 date, watched it move, and quietly stopped work [15].
The Dutch version is the most literal. On June 16 the senate adopted bill 36.783, presuming employment for work paid below 38 euro an hour against a reference date of January 1, 2026 [16]. When a self-employed worker invokes it, the hiring company proves no employment relationship exists, or the worker gains sick pay continuation and dismissal protection [17]. Enforcement resumed in 2025 after a decade-long moratorium, corrections reach back to January 1, 2025, and the remaining leniency expires on January 1, 2027 [18]. The evidence that wins that argument is rate history, scope documents and scheduling records for an individual contractor, held for years, retrievable by name.
What sorts the work for each date comes down to two things: which system holds the record for one named person on one named day, and whether it survives the manager who made the decision leaving. The other question is whether the record was written at the moment of the decision or reconstructed afterwards from memory and email. Anything reconstructed is a policy document wearing an evidence costume, and under a reversed burden the company is the one holding it.
