Country guide
Pay transparency in Germany
What the EU Pay Transparency Directive means for employers in Germany, based on its national transposition — status, thresholds, the joint-assessment trigger, and where to file.
Germany has not published a directive transposition bill as of June 2026 (deadline missed); an expert commission on low-bureaucracy implementation delivered its final report in October 2025, but no draft bill has followed it. The existing Entgelttransparenzgesetz (EntgTranspG 2017) remains in force; under ECJ direct-effect case law the Directive already binds public-sector employers.
Germany has not yet transposed the directive, and the 7 June 2026 deadline has passed. The directive's own thresholds are the best guide until national law is enacted; any pre-existing national pay-reporting regime continues to apply in the meantime.
Reporting duties apply by employer size: More than 500 employees, from 2018 · Every five years, further conditions apply; 150 or more employees, from 2027 · Every three years (anticipated); 250 or more employees, from 2027 · Annual (anticipated); 100 or more employees, from 2031 · Every three years (anticipated). The directive's 5% trigger for a joint pay assessment applies until national law sets its own.
The pay-gap figures must be published, not just filed with the authority. Either way, the underlying work is the same: establish work of equal value through gender-neutral job evaluation, produce the statutory pay-gap report in the national format, and run a joint assessment where the gap is too wide.
Obligations at a glance
| Reporting threshold |
|
|---|---|
| Joint pay assessment | — |
| Public publication | Required |
| Competent authority | — |
Frequently asked
Is the EU Pay Transparency Directive in force in Germany?
Germany has not yet transposed the directive, and the 7 June 2026 deadline has passed. The directive's own thresholds are the best guide until national law is enacted; any pre-existing national pay-reporting regime continues to apply in the meantime.
Which employers have to report in Germany?
Reporting duties apply by employer size: More than 500 employees, from 2018 · Every five years, further conditions apply; 150 or more employees, from 2027 · Every three years (anticipated); 250 or more employees, from 2027 · Annual (anticipated); 100 or more employees, from 2031 · Every three years (anticipated).
What triggers a joint pay assessment in Germany?
The directive's 5% trigger for a joint pay assessment applies until national law sets its own.
This guide summarises publicly available information for orientation only. It is not legal advice — confirm every figure against Germany's own transposition text before relying on it.