Germany pay transparency status
Last reviewed 2026-10-16
No published transposing law
Germany has no published transposing statute in the 23 September 2026 snapshot. This page is a thin status note and is not promoted.
Germany (Deutschland, DE), capital Berlin, EU member since 1958. Snapshot: A draft law has been prepared but has yet to be published.
What applies by employer size
Nothing in these size bands is current national law in Germany. They restate the Directive floor so a reader can see what transposition would impose. A draft, an internal text, or a government target date is not an employer duty.
Fewer than 100 workers
Article 9 gender pay-gap reporting does not start below 100 workers. Article 5 (pay range or starting pay for applicants, and no pay-history questions) and Article 7 (worker right to pay-level information) are not limited to employers of 100 or more. That is the Directive floor, not a statement that the Member State already imposes it.
100 to 149 workers
Article 9 requires the employer to report the gender pay gap every three years. The Directive sets the first report for 7 June 2031. Joint pay assessment under Article 10 can follow an unjustified gap of at least 5 percent. National law must transpose the duty before it binds a private employer.
150 to 249 workers
Article 9 requires the employer to report the gender pay gap every three years. The Directive sets the first report for 7 June 2027. The same Article 10 joint-assessment rule can apply. National law must transpose the duty before it binds a private employer.
250 or more workers
Article 9 requires the employer to report the gender pay gap every year. The Directive sets the first report for 7 June 2027. The same Article 10 joint-assessment rule can apply. National law must transpose the duty before it binds a private employer.
Deadlines
Transposition deadline for Member States
7 June 2026
Directive (EU) 2023/970. A missed deadline does not by itself create private-employer duties. Source
First Article 9 report, 250 or more workers
7 June 2027, then yearly
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
First Article 9 report, 150 to 249 workers
7 June 2027, then every three years
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
First Article 9 report, 100 to 149 workers
7 June 2031, then every three years
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
Rules on 2026-10-16
Resolved from rule pack version 2026-09-23. Status is enacted, partial, draft, or none. A future effective date is not in force yet.
Pay range for applicants (Article 5)
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 5 requires applicants to receive the initial pay or its range. The Directive does not limit this to employers of 100 or more. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
No pay-history questions (Article 5)
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 5 prohibits asking applicants about their pay history. The Directive does not limit this to employers of 100 or more. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Worker right to pay-level information (Article 7)
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 7 gives workers a right to information on their pay level and average pay levels by sex for the same work. The Directive does not limit this to employers of 100 or more. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — fewer than 100 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 9 does not require gender pay-gap reporting below 100 workers. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 100 to 149 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 100 to 149 workers the Directive sets the first report at 2031-06-07. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 150 to 249 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 150 to 249 workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 250 or more workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 250 or more workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — fewer than 100 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 9 does not require a joint pay assessment below 100 workers. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 100 to 149 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 100 to 149 workers the Directive sets the first report at 2031-06-07. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 150 to 249 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 150 to 249 workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 250 or more workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Germany: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 250 or more workers the Directive sets the first report at 2027-06-07. Snapshot: A draft law has been prepared but has yet to be published. A draft or a missing statute is not an employer duty.
Sources
- Directive (EU) 2023/970 on pay transparency (as of 2023-06-06)
- Lockton, EU Pay Transparency Directive — implementation status (table as of 23 September 2026) (as of 2026-09-23)
Directive guides · Gender pay gap calculator
Informational only. This is not legal advice, not a legal opinion, and not a substitute for reading the national statute or instructing counsel. Statutory claims on this page cite Directive (EU) 2023/970 or the Lockton status snapshot and carry a last-reviewed date.