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.

By Paritir · Last updated 28 September 2026

Not yet transposed

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.

Germany sets reporting duties by employer size; the table below lists each band as the law states it. 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
EmployeesFromCadenceStatusSource
More than 500 employees, further conditions apply 2018 Every five years Confirmed Enacted · read 3 September 2026 · matches the text we hold
150 or more employees 2027 Every three years Anticipated
250 or more employees 2027 Annual Anticipated
100 or more employees 2031 Every three years Anticipated
Laws in force
Joint pay assessmentThe directive's 5% trigger for a joint pay assessment applies until national law sets its own.
Public publicationRequired

How this data is sourced →

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?

Germany sets reporting duties by employer size; the table below lists each band as the law states it. More than 500 employees, from 2018, every five years, further conditions apply.

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 the national transposition text (Germany) before relying on it.

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