Salary transparency law transposed into French rules

Published 2026-10-20

A bill on salary transparency was presented in the Conseil des ministres. That is a real legislative step, but it is not a settled set of rules a founder can comply with today. Treating a cabinet presentation as a finished law is a mistake we see founders make with almost every piece of French employment news that crosses their feed.

What is already locked in, with real penalties attached, sits elsewhere: the DPAE, the social charges, the mutuelle, and the collective agreement that quietly sets the real floor on pay. None of that is waiting on parliament. It applies the day a founder hires their first employee, so that is where this article puts its weight.

What actually happened: a bill, not a law

A projet de loi presented in the Conseil des ministres means a government-sponsored bill has started its parliamentary path. It has not been voted, it has not been published, and it has not been transposed into the Code du travail, which means nothing in it is enforceable yet.

We cannot verify the bill's substantive content, including any pay-range disclosure rules, the format of pay-equity reporting, penalty amounts, or a transposition deadline, so this article states none of them. If a founder needs the final mechanics, the only responsible move is to wait for the adopted text and check it directly rather than act on cabinet-stage reporting.

The likely backdrop is the EU-level push toward pay transparency, since France, like other member states, is expected to transpose EU rules into domestic law at some point. But the specific French mechanics, thresholds, and dates are not yet confirmed in anything we can verify, so they stay out of this piece until they are.

What is already mandatory when you hire your first employee in France

Three obligations are not up for debate, regardless of what happens to the transparency bill.

DPAE (Déclaration Préalable à l'Embauche): mandatory, filed within the 8 days before the hire starts, at the latest just before the employee's first day, via urssaf.fr or net-entreprises. It registers the employee with URSSAF, affiliates them to occupational medicine, and activates workplace-accident cover. Skip it and the exposure is travail dissimulé, undeclared work, which is a criminal offence, not a late fee.
URSSAF: the body that collects employer and employee social contributions. The employer registers and declares monthly, or quarterly for very small companies, and this is the backbone of every subsequent payroll obligation.
Mutuelle (collective complementary health cover): mandatory for all private-sector employers since 1 January 2016 under the 2013 ANI agreement. The employer pays at least 50% of the premium, and the plan must meet the panier ANI minimum cover. A handful of exemptions exist, such as an employee already covered through a spouse's plan or certain apprentices, but the default is coverage, not optionality.

These three items are due before day one, not after the business starts generating revenue, which is exactly where founders who formed a company fast and deferred payroll thinking get caught out.

The real floor on pay: convention collective, not just SMIC

The number most founders anchor on is the SMIC. The number that actually governs the first hire is usually the applicable convention collective.

A CCN, a sector-level collective bargaining agreement, applies based on the company's real main activity, not simply the APE or NAF code stamped on the KBIS. Where a CCN covers that activity, applying it is mandatory, full stop, and the code is only a starting indicator a founder still has to verify against what the business actually does.

A CCN sets minimum salary grids, job classifications, notice periods, severance terms, working-time rules, and sometimes a 13th month, all layered above the statutory Code du travail floor. It has to appear on the payslip, and employees have to be informed of which one applies to them, which means this is not a background detail a founder can leave undocumented.

Tech and SaaS companies frequently fall under SYNTEC (bureaux d'études techniques), but that has to be confirmed case by case against the company's real principal activity. Some companies have no branch CCN at all, in which case only the Code du travail applies, so a founder should not assume SYNTEC by default just because the business writes software.

On the SMIC itself: as of 1 June 2026 it stands at €12.31 an hour gross, €1,867.02 a month gross on a 35-hour week, roughly €22,404 a year gross. It was €1,823.03 a month and €12.02 an hour between 1 January and 31 May 2026 before the mid-year bump, because the SMIC is revalued every January and gets an automatic additional bump mid-year whenever inflation exceeds 2%. Evergreen hiring copy should say "at least the SMIC" rather than quoting a hard figure, since this number moves on a schedule a founder cannot control.

Before writing a job posting for your first hire, confirm the route and the numbers directly: check your eligibility.

What pay transparency usually means in practice, and why founders should prepare now anyway

Without quoting unverified French specifics, the general shape such rules tend to take elsewhere is predictable: salary ranges disclosed in job postings, pay-equity information made available to candidates or employees, and meaningful exposure for employers who cannot produce the underlying data when asked. France's eventual text may land differently in its particulars, but the general direction is not a surprise to anyone watching EU employment policy.

A pattern we see with founders who build payroll reactively: no documented salary bands, no written rationale for why one hire earns more than another doing comparable work, and a scramble the moment a new obligation lands in the news. That scramble is avoidable, and avoiding it costs nothing extra beyond doing the groundwork once, properly, at the first hire.

Getting the CCN classification and the salary grid right from hire one is not just a compliance checkbox. It is also the natural documentation base for any future pay-range disclosure requirement, so a founder who does this correctly now treats the eventual law as paperwork, not a crisis.

The cost structure a founder is actually committing to

Employer charges run approximately 40 to 45% of gross salary, higher for cadres, which means total employment cost runs roughly 1.40 to 1.50 times gross, or about 1.80 to 1.90 times net. A founder quoting a €40,000 gross salary is committing to something closer to €56,000 to €60,000 in total cost, not €40,000, and that gap is where budgets quietly break.

This connects directly to the transparency conversation, because a founder who has to disclose a salary range to candidates needs to already understand the full loaded cost, not just the headline gross figure printed in the posting. A range that looks competitive on paper can be unsustainable once the employer-side charges are added, which means the range itself was never real to begin with.

The mistake we see again and again: a founder posts a gross salary figure lifted straight from a competitor's job ad without running it through their own employer-cost math or checking it against their applicable CCN grid. The result is a number that is either illegal under the CCN floor or unaffordable once the 40 to 45% lands on top of it, and discovering that after the posting goes live is the expensive way to learn it.

Director salary and its second life: visa renewal

For founders on either Talent route, the mandataire social's own salary level matters beyond payroll compliance, because it functions as an income and viability signal that authorities weigh when renewing the Talent permit. A business that cannot show the director is paying themselves something defensible raises questions at renewal that a clean salary history would have avoided.

In our experience, founders who build documented, defensible salary practices for their employees tend to also build the clean paper trail that supports their own renewal file later, because the discipline is the same: real numbers, real documentation, tied to a real CCN or market rate, not figures invented to look good on paper.

Renewal is not automatic regardless of how the business is doing, and no specific salary threshold should be quoted without verification from an accountant, since this varies with circumstances that a generic article cannot responsibly reduce to one number. Treat director compensation as part of the same compliance discipline as employee payroll, not a separate, lower-stakes decision.

What to do now, while the bill is still moving

Confirm the applicable CCN before the first hire, checking the company's real principal activity rather than assuming the APE or NAF code settles it.
File the DPAE within the 8-day pre-hire window, at the latest just before the employee's start date.
Set up the mutuelle at or above the panier ANI minimum, with the employer covering at least 50% of the premium.
Build the full loaded-cost model, roughly 1.40 to 1.50 times gross, before writing a single line of a job posting.
Revisit this topic once the transparency bill is actually adopted and published, not while it sits at the cabinet-presentation stage, and check the current state of the law before acting on anything reported as "coming."

Hiring your first employee in France is where a lot of founders discover that "I'll figure out payroll once I have a KBIS" was the wrong plan, because the DPAE, the mutuelle, and the convention collective all have to be right before someone's first day, not after. Nounda's first-90-days support picks this up as part of the same engagement that handles company formation and the visa dossier, so a founder isn't left reading service-public.fr alone the week a new law lands in the news. If the salary transparency bill becomes law with concrete disclosure obligations, Nounda will fold that into the same hiring playbook rather than treating it as a separate fire to put out. For current scope and pricing, go to nounda.com/pricing.