Why a director’s pay is stated in New York and almost never in Britain

On 5 November the British government announced that it will oblige employers to state pay in job ads, and the Prime Minister urged companies to start now, without waiting for the law. The law itself does not exist yet. Whom it will cover, what exactly will have to be stated and how compliance will be checked are to be announced later. The press release cites a survey by the CIPD, the British professional body for HR. By that survey, in 2024 only 41% of employers always published a salary range.

TOPHEADS dataThe government gives no figures for executives. We counted them ourselves. From 28 September to 31 October we collected 1,766 new British executive vacancies, director level and above, from company career sites. Pay was found in 111 of them, that is 6.3%. This cannot be compared directly with the survey: employers there were asked about all positions, while we counted ads for executive hires. But the order of magnitude is clear. For executive vacancies the law would, in effect, create the practice almost from scratch.

The first explanation that comes to mind: Britain simply has different employers. To test it, we selected 256 companies that hire executives both in Britain and in New York or California.

Of these 256 companies, 168 state pay only in their American ads, 15 in both countries, 2 only in their British ads, and for 71 we found it nowhere. The employer is the same, yet the gap remains. The positions inside one company are, of course, different, so this comparison alone is not proof, but it fits the idea that the law is the reason. Something else stands out: these 256 companies’ British share, 4%, is lower than that of the other British employers, 8.3%. Companies that also hire in America stay silent in Britain more often than the rest.

The second explanation: this is simply how things are done in America, and the law has nothing to do with it. That can be tested inside the US itself. We took 15 states where state law does not require pay in the job ad, among them Texas, Florida, Georgia and Pennsylvania. There pay was found in 25.3% of executive vacancies, against 66.5% in New York and California. Here all companies count, not just those 256, which is why the New York and California figure differs from the first chart. The gap is large, and it holds if we keep only the companies that hire both in these states and in New York or California. An American habit alone cannot explain it. As for pay still appearing in every fourth vacancy in states without the law, that can be explained. A company obliged to state pay in New York often does so across the whole country, and if a vacancy is remote, New York or California law may apply to it. Both explanations are guesses for now; we have not tested them.

The third explanation: in Europe people simply do not talk about money. By 7 June the EU countries were due to write the requirements of the EU pay transparency directive into their own laws. Most did not make it. Those that did went about it differently.

Italy made it mandatory to state the starting pay or its range in the ad, and for executives too. On career sites in Italy pay was found in 24 executive vacancies out of 62, that is almost 40%. In 6 of those 24 only the lower bound is given, “from such-and-such a sum”, but that too is a figure in the ad. Germany, France and Spain have no such law yet, and their shares are 4.2%, 6.0% and 5.6%.

The data on Italy is thin, so we looked at it from two more angles. First we took 28 companies that hire both in Italy and in Britain. In their Italian ads they state pay in 14 vacancies out of 36, in their British ads in 2 out of 110.

Then we took data from the analytics firm Revelio Labs. It counts all ads, across all positions. In April it found pay in 28.6% of Italian ads, in May in 34.8%. In June, when the law took effect, the share jumped to 44.8%, and by September to 48.0%. The rise began before the law, but the biggest jump came in June.

In the EU countries that have no such law yet, the picture across all positions is mixed. According to Revelio, pay is stated in 43% of ads in France and 59% in the Netherlands, but in only 20% in Germany and 19% in Spain. And that answers the third explanation. For mass-market positions France and the Netherlands state pay without any law, but not for executives: among executive vacancies France is at 6.0% and the Netherlands at 5.5%, 9 vacancies out of 164. In Italy, where the law requires a figure in the ad, executives are at almost 40%. In Poland the law allows pay to be disclosed later, before the interview or before the contract is signed, and Revelio sees it in 4% of ads there. Among executives we found it in 12 vacancies out of 99, but 5 of them belong to one company, and without it the share is close to the countries without such a law.

So far the picture is this. Among the same companies the gap between New York and Britain is huge, inside the US it holds between states with the law and without it, and in Europe a figure appears in the ad where the law requires it. Neither an American habit nor European reticence explains this. The simplest explanation left is the law that requires pay in the ad itself. Comparing countries cannot prove it; we have not separated the law from other differences between them. It can be tested on Britain itself. If the law is passed in the promised form, the share of executive vacancies with pay should rise, and we will count it the same way once the law takes effect.

What this means for you. The Downing Street press release speaks specifically about ads, as in the US and Italy. If the law keeps that wording and comes without exceptions, directors’ pay may appear in British ads quickly. If instead it allows pay to be disclosed later, there will most likely be little of it in ads, as in Poland. So two things matter in the future law: where pay will have to be disclosed, in the ad or in conversation, and whether there will be an exception for executive positions. Such exceptions exist. Austria requires the minimum pay to be stated in the ad. But the government portal explains that where there is no collective agreement, this rule does not cover executives, directors for example.

For candidates. Before a conversation about a position in London or another European city, open the same company’s ads in New York and California. They will show how the company values similar positions and give you a reference point for the conversation. Do not convert dollars into pounds at the exchange rate: the markets are different, and the rate is beside the point. In Italy pay must be stated in the ad itself. In Poland it must be disclosed at the latest before the contract is signed, and in Greece before the interview, so you can ask about it directly.

For the employer. Staff in your European offices can already see what the company offers in the US, and their questions will most likely arrive before the law does. Pay levels across countries are worth aligning now, while it can be done without haste.

In the first issue we found that, by published ranges, a Senior Director’s pay is higher than a VP’s. Now we have checked this within companies. 272 companies have published ranges for both positions, and in 230 of them, roughly 85%, the VP range is higher. Inside a company the ladder is where it should be.

We now have three times as many ranges in North America as in the first issue, 14,528 against 4,412, and across the whole sample the ratio is unchanged: $247k for Senior Director, $215k for VP. The reason is the make-up of the sample. Senior Director ranges are published more often by the companies that pay more, and at those companies the VP midpoint is $256k, at the others $205k. The same effect shows for SVP and EVP, who are below Senior Director across all ranges but above once each company gets one vote. Throughout, this is the midpoint of the published base pay range; bonus and equity are not in it. On top of that, level titles mean different things at different companies and in different industries, so comparing positions by title alone, without the company, is not enough.

One more observation, not yet a conclusion. At companies with finance words in their name, the VP midpoint is roughly $35–50k lower than at the rest. Industry by company name is a crude measure, but a VP at a financial company and a VP at a technology company are, it seems, different money, and the range does not show the bonus. So compare specific companies: a job title alone will tell you little.

On 2 September Uber announced it was cutting about 3,300 jobs, 10% of its staff. There will be 20% fewer managers, and the number of employees seven or more layers down from the CEO has, according to its chief executive, already been reduced by 20%. If cutting management layers reduces demand for directors, there should be fewer director vacancies. On Uber’s site that is not visible. In the 20 days before the announcement, 11 vacancies at director level and above appeared there, in the following 30 days 19, and in the next 30 days 23. Per week that is roughly 3.9 ads, then 4.4 and 5.4. No decline. But an ad is not yet a new position: how many executives the company actually hired, and how their number changed, cannot be read from vacancies. And so far this is one company.

Uber is not the only one removing layers. NICE, the Israeli maker of customer service software, said on 4 November that it is removing management layers, and Schaeffler, according to Handelsblatt, is removing at least two of seven. This cannot be tested against vacancies yet; both announced their cuts after the end of our count. Artificial intelligence, meanwhile, is cited as the reason for cuts less often than in the spring.

These are the companies’ own words, and one month without a big announcement moves the figure several times over. And “we are removing layers” does not yet mean that directors are not being hired. At an interview it is useful to ask how many people will report to you and whom this position replaces. Companies that have announced a flat structure and are opening director vacancies would do well to explain in advance how the new position differs from the ones cut: candidates have read those announcements.

Let us start with a correction. In No. 1 we gave two possible dates from which the new New York State law applies, because lawyers read it differently. Now the state’s Department of Labor has named the date: the law applies from 19 December 2026 to agreements entered into from that day and to new or amended terms in existing ones.

The rule is this. Repayment of a signing bonus can be required if the employee leaves voluntarily or is dismissed for misconduct. If the position is eliminated, or the employee is dismissed for any reason other than misconduct, repayment cannot be required. There is also a separate exception. If the employee left voluntarily because the employer misrepresented the duties or requirements of the job, repayment is not allowed either. The Department defines misconduct as behaviour detrimental to the employer’s interests or in violation of a reasonable work condition, and that includes what the employer’s own policy calls a “for cause” termination. So that policy is worth reading. The law makes no exceptions by income or industry: it covers all employees.

California introduces a similar rule from 1 January 2027 for agreements signed from that date. Repayment on a layoff is prohibited there too. In other cases it is possible only under a separate agreement, the sum is reduced in proportion to the time worked, the retention period is no longer than two years, and no interest accrues. Before signing, the employee is given five business days to consult a lawyer. Salespeople and agents of broker-dealers, insurers and investment advisers have their own terms there.

Companies are cutting staff, and people hired with a bonus will fall under these rules. In other jurisdictions the answer is different, and it is important to separate two questions: whether the employee must repay the bonus, and whether the employer may deduct it from wages.

If you are signing a job offer with a bonus in November, the signing date matters. Discuss with a lawyer which date counts as the conclusion of the agreement, how misconduct is defined, whether the bonus is structured as a loan and whether repayment is reduced in proportion to the time worked. Those who hire need a new contract template by 19 December in New York and by 1 January in California, and an offer with a repayment clause in California should be planned with five business days to spare.

The three most prominent appointments of the week went to outsiders who have already run large companies: Euronext is nominating the head of insurance group NN, HP has called in the former head of pharmaceutical company GSK, and Asda the former head of the Morrisons chain. Two of the three come from a different industry. The list is compiled by hand, big names are over-represented in it, and two cases prove nothing. But the boards of two large companies looked beyond their own industry this week.

On 3 November Binance described how the attack unfolded. In June a developer on the wallet team downloaded an infected tool. The device was replaced, but the attackers already knew who on the team was responsible for what. In September another engineer, who was looking for a job, went through an interview for a non-existent position, met online with the “CEO” of a made-up company and downloaded malicious code. On 20 October, from his computer, the attackers reached the systems of two developers, and on 29 October they began the theft, which cost the exchange about $6.3bn. Fortune, citing the exchange’s executives, writes that the engineer was found on LinkedIn. The exchange bars employees in non-public-facing roles from having such profiles.

The job search itself is not the problem. The danger is code run at the request of strangers. One such run cost the employer billions, and this concerns more than crypto companies. If you work with payments or have access to important systems, a test assignment from an unfamiliar company must never be run on a work computer, and the company and the interviewer are worth checking before the second call. Employers should warn their people about fake recruiters in advance.

This week two companies are hiring executives for regulated businesses: the person is responsible for the company’s finances or risks and represents it before the regulator.