Overview
- Germany failed to transpose the EU pay‑transparency directive by the 7 June 2026 deadline, and the government announced on Friday that it will aim for a slimmer national law in 2027 with staggered company deadlines.
- Under the planned timetable larger firms will face reporting duties later than the EU timetable, with many employers given until mid‑2028 to meet reporting obligations and firms of 100–149 employees potentially granted until 2031 to file their first reports.
- The EU rule requires employers to give applicants an entry salary or salary range and bans asking candidates about past or current pay, and it also lets staff request the average pay of comparable workers broken down by gender and the objective criteria used to set pay.
- Employers are already seeing more pay‑related inquiries and legal risk after recent German court rulings, and lawyers advise firms to document gender‑neutral, objective pay criteria to defend against discrimination claims.
- Key legal questions remain unresolved about how the directive will interact with collective bargaining and market‑driven pay differences, and Germany’s narrower approach could prompt EU scrutiny or future court challenges while workers wait for stronger national rules than the 2017 law.