Pay transparency in Germany
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Pay information requests In preparation
Statistical comparator and pay criteria under the existing Entgelttransparenzgesetz, generally in establishments with more than 200 employees
No published draft text yet.
Germany is still at the preparation stage for transposing the EU Pay Transparency Directive. As of the most recent update, there is no published government draft or Referentenentwurf setting out how the Directive’s rules will work in German law.
What is already in force is the 2017 Entgelttransparenzgesetz, Germany’s existing pay transparency act. It gives employees narrower rights than the Directive eventually will, and it applies at higher employee thresholds than the Directive proposes.
The federal government has said that implementation questions are still being clarified and that the legislative procedure will start once that work is done. Until a draft is published, employers should treat any Directive-specific obligation in Germany as not yet defined.
The measure
- Law or measure
- Official preparation for a transposition bill; no published government draft or Referentenentwurf identified
- Core obligations start
- Pending
- Who is covered
- Existing Pay Transparency Act has narrower thresholds; full Directive-wide scope remains pending
What the law requires
- Pay information requests
- Gap reporting from More than 500 under existing EntgTranspG employees
2 further dimensions are still being verified against official sources.
How Germany differs from the Directive
No published Directive-specific draft is available. The 2017 Entgelttransparenzgesetz remains in force as a narrower pre-existing regime.
What this means for employers
For now, your compliance baseline in Germany is the existing Entgelttransparenzgesetz, not the EU Directive. That law already gives employees a right to pay information, and it sets reporting and comparator duties at its own thresholds, which are higher and narrower than what the Directive will eventually require.
- Keep your existing Entgelttransparenzgesetz processes running: individual pay information requests, and any reporting or comparator obligations that apply at your current employee count.
- Do not assume a draft exists: no Referentenentwurf has been published, so any Directive-specific obligation, deadline, or threshold for Germany is pending and should not be built into your compliance plan yet.
- Watch for the Referentenentwurf: once a draft is published, it will set out how Germany applies the Directive’s rules on salary ranges, salary history, and reporting, which are not yet defined for Germany.
- Note who enforces what today: the Federal Ministry for Family Affairs, Senior Citizens, Women and Youth and the Federal Ministry of Labour and Social Affairs are involved on the government side, and the Federal Anti-Discrimination Agency is the equality body.
Preparing early means separating what is legally required now under the existing Act from what is only proposed under the Directive. That distinction will matter once Germany’s transposition bill is actually published.
Enforcement and open questions
- Competent authority
- Federal Ministry for Family Affairs, Senior Citizens, Women and Youth; Federal Ministry of Labour and Social Affairs
- Equality body
- Federal Anti-Discrimination Agency
- What could still change
- The federal government stated on 16 July 2026 that implementation questions were still being clarified and the legislative procedure would begin afterward.
Common questions
Has Germany published a law implementing the EU Pay Transparency Directive?
No. Germany is at the official preparation stage, and no government draft or Referentenentwurf has been published yet. The federal government has said implementation questions are still being clarified before the legislative procedure begins.
What pay transparency rules currently apply to employers in Germany?
The existing Entgelttransparenzgesetz from 2017 is the operative law. It gives employees a right to pay information and sets narrower reporting and comparator duties than the EU Directive, applying at higher employee thresholds than the Directive proposes.
Do employees in Germany already have a right to request pay information?
Yes, under the existing Entgelttransparenzgesetz. This is a pre-existing national right, separate from the EU Directive, which Germany has not yet transposed.
When will Directive-specific reporting deadlines apply in Germany?
That is not yet defined. Reporting currently follows the existing Entgelttransparenzgesetz cycle, and the Directive's own dates for Germany are pending publication of a transposition bill.
Who enforces pay transparency rules in Germany?
The Federal Ministry for Family Affairs, Senior Citizens, Women and Youth and the Federal Ministry of Labour and Social Affairs are the competent authorities on the government side. The Federal Anti-Discrimination Agency serves as the equality body.
Should employers in Germany start preparing for the EU Pay Transparency Directive now?
It helps you prepare to maintain your existing Entgelttransparenzgesetz duties and monitor for the publication of a Referentenentwurf. Since no draft exists yet, treat any Directive-specific obligation for Germany as pending rather than in force.
- Pay information request right Art. 7(1)
- In preparation
Statistical comparator and pay criteria under the existing Entgelttransparenzgesetz, generally in establishments with more than 200 employees
Germany already has an employee pay-information right under the pre-existing Pay Transparency Act; this does not establish full Directive transposition.
Still being verified against official sources: response deadline, salary range in recruitment, salary history questions banned, joint pay assessment trigger.
- Reporting threshold
- More than 500 under existing EntgTranspG employees
- Reporting model
- Pre-existing national reporting Operational data-production and filing model for pay-gap reporting: employer-calculated, authority-calculated, hybrid, proposed, pre-existing or absent.
- Metrics required
- Different / modified Art. 9(1): Seven metrics: mean gap; variable-component gap; median gap; median variable gap; variable-pay participation by sex; quartile distribution by sex; category-level gap split basic and variable.
- Pre-existing regime
- Existing Entgelttransparenzgesetz provides narrower information/reporting rights at higher thresholds.
- Formal transposition stage
- Official preparation
- Scope
- Pre-existing regime only
Next milestone
Maintain Entgelttransparenzgesetz duties and monitor publication of a Referentenentwurf.
Primary sources
- Official preparation for a transposition bill; no published government draft or Referentenentwurf identified Primary source, checked 7 August 2026
- Formal transposition stage Official preparation · preparation · high confidence
- Core employer obligations Official preparation · preparation · high confidence
- Transposition scope Pre-existing regime only · pre existing · high confidence
- Pay information request right Yes · pre existing · high confidence
- Reporting threshold More than 500 under existing EntgTranspG · pre existing · high confidence
- Reporting model Pre-existing national reporting · pre existing · high confidence
Change history
This page is maintained by Evenpay from official primary sources and reviewed before publication. It is general information, not legal advice. Requirements vary by member state and change as national laws progress; figures described as proposed are subject to amendment.