🇫🇷 France · 🇦🇺 Australia
By Priya Mehta, The Global Office
Australia made pay-secrecy clauses illegal in employment contracts back in December 2022, giving every worker an explicit legal right to ask a colleague what they earn. France, by contrast, is only now transposing an EU directive that will require salary ranges to appear directly in job postings, with the law still working its way through parliament in 2026, past its original June deadline. Both countries are moving toward transparency by regulation rather than habit, which tells you something important: neither culture ever got there through comfort alone.
| ✅ Do | ❌ Don't |
|---|---|
| Let the recruiter raise salary first — it's traditionally their move, not yours | Volunteer a specific number early; offer a range if pressed |
| Research industry benchmarks before your annual review — that's the real negotiation moment | Expect off-cycle raises outside the formal entretien annuel |
| Ask about the 13th-month salary, meal vouchers, and profit-sharing separately from base pay | Treat base salary as the full picture of total compensation |
| Get every verbal promise in writing before resigning your current role | Trust a verbal offer as final — French hiring has real gazump risk |
| Watch for salary ranges appearing directly in job postings as the new law rolls out | Assume the old "ask at interview" norm will hold much longer |
| ✅ Do | ❌ Don't |
|---|---|
| Exercise your legal right to ask colleagues what they earn if you want to | Assume asking is illegal or even unusual anymore — the law changed in 2022 |
| Negotiate directly and firmly; Australians respect bluntness here | Assume enthusiasm about an offer weakens your negotiating position |
| Take 24–48 hours before accepting, even a great offer | Accept on the spot out of politeness — it's a normal ask to pause |
| Use Seek, Glassdoor, and Payscale data explicitly in your pitch | Negotiate purely on vibes without citing comparable market data |
| Remember visa income thresholds are a floor, not your target salary | Assume a sponsored role's minimum threshold is the actual market rate |
French salary culture has long treated compensation as something raised carefully and at the right moment, typically the annual performance review, rather than something openly compared between colleagues. That's now being forced open by regulation: the EU Pay Transparency Directive, which France must transpose, will require salary ranges in job postings and ban employers from asking candidates about previous pay, while reversing the burden of proof in pay-discrimination disputes onto employers. France is going further than the EU minimum, lowering the reporting threshold from 100 to 50 employees, which sweeps far more small and mid-sized companies into the transparency requirement.
The practical guidance for a newcomer still reflects the older norm: let the recruiter broach salary, typically near the end of the interview, and respond with a range rather than a fixed number if pressed early. Job offers in France also carry a specific risk foreign candidates underestimate — verbal agreements on salary and benefits have, in documented cases, evaporated before contracts were signed, making "get it in writing" more than boilerplate advice.
Australia legally dismantled pay secrecy in one clean legislative move: since December 2022, pay secrecy clauses in contracts have no legal effect, and workers have an explicit right to disclose or ask about pay, with real financial penalties (currently up to roughly $93,900 for a corporation) for employers who violate it. And yet, as research covered by The Conversation documents, Australians still overwhelmingly don't ask — a persistent "salary taboo" that survived the law change largely intact. The gap between legal right and social habit is the whole story here.
The Morning Brief
Enjoying this? Get it in your inbox.
Negotiation itself, once you're actually in a live conversation with an employer, runs more openly than the pay-secrecy taboo would suggest: guides for relocating professionals consistently describe Australian hiring managers as receptive to direct, data-backed asks, and taking time to consider an offer before accepting is treated as completely normal rather than presumptuous.
The irony is almost a mirror image: France has the more codified, EU-driven regulatory push arriving now, in a culture where salary discussion has traditionally been handled formally and privately; Australia had the more radical legal reform three years earlier, in a culture that still won't quite use the right it was given. Hofstede Insights scores France higher on uncertainty avoidance (86) than Australia (51), which tracks with the French preference for structured, review-cycle-bound negotiation over the more improvisational, ask-anytime culture technically available in Australia.
For a newcomer, the practical result is that Australia gives you more legal cover to be direct but requires you to overcome a cultural inertia that even locals haven't shaken; France gives you less legal cover today but a very clear, imminent structural change that will make salary ranges visible before you ever sit down for an interview.
MisterBilingue (career guide for English speakers in France) — One contributor described the awkwardness of a French recruiter visibly recalibrating when asked directly about salary range early in a first call, confirming that raising the topic first still reads as a minor breach of interview etiquette even among younger hiring managers.
Quora — A relocated professional described the specific shock of having a verbal job offer, salary and start date included, quietly disappear a week before signing, learning the hard way that nothing in French hiring is real until the contract is signed.
The Local France — A British expat's account described negotiating the 13th-month salary and meal voucher value as more consequential to her final take-home pay than the base salary figure itself, something her interview prep hadn't covered at all.
SyncSkills (Australian immigrant negotiation guide) — A migration case study noted that visa-sponsored candidates frequently anchor to the government's minimum skilled-migration income threshold without realizing it's a floor, not a competitive offer, leaving real money on the table.
Michael Page Australia — A recruiter-authored account described candidates responding to Australian directness with visible discomfort at first, since blunt pay conversations read as aggressive coming from cultures where salary talk stays more private, before most adjusted within a few negotiations.
The honest takeaway is that neither country makes this easy in the way its laws suggest it should. In Australia, you have every legal right to ask what your Sydney colleague earns, but you'll likely be the one breaking an unspoken rule if you do. In France, you're arriving just as the rules are about to become dramatically more transparent, but until they land fully, the old etiquette, patience, indirection, and getting everything in writing, still governs. If a friend asked me which to prepare for, I'd say: in Australia, practice asking directly even when it feels rude; in France, practice waiting even when it feels passive, because in each case the discomfort is the actual skill you're building.
Subscriber Only
Subscribe to The Alignment Times and get every article delivered to your inbox.
Photo by www.kaboompics.com via Pexels
Priya Mehta
Staff writer covering financial markets and corporate strategy. Has strong opinions about spreadsheets.