Pay transparency: The clock is ticking — what companies need to do now.

The EU Pay Transparency Directive (2023/970) must be implemented by 7 June 2026. The changes are significant and affect virtually every employer in Germany.

Right to information without a threshold
In future, all employees, regardless of the size of the organisation, will have the right to information about their pay and the average pay of comparable groups. Previously, this only applied to companies with 200 or more employees.

Salary details to be included in job advertisements
Starting salaries or salary ranges must in future be proactively communicated, based on objective, gender-neutral criteria. Asking about previous salaries will be prohibited.

Reporting obligations from 100 employees
The threshold is being lowered from 500 to 100, with tiered reporting on specific indicators of the pay gap.

Companies that act now can establish clear structures and avoid future risks: reversal of the burden of proof, unlimited claims for damages and public reporting obligations. Performance-related pay remains possible provided it is documented and consistent.

Would you like to know where your company stands? I look forward to hearing from you.
Markus Bettecken mb@haver-mailaender.de
Partner | Employment Law & Litigation