Germany Pay Transparency Law: EUPTD Transposition Status
Local term: Entgelttransparenz
As of 28 September 2026: At last check, Germany had not published an official draft bill. Cabinet approval of amendments to the Pay Transparency Act (Entgelttransparenzgesetz) was postponed from June 2026. The existing 2017 Act continues to apply.
Status snapshot
| Status | No draft yet |
|---|---|
| National instrument | Amendment of the Pay Transparency Act (Entgelttransparenzgesetz). No government draft published; cabinet approval has been repeatedly postponed. |
| Official source | No draft legislation published at last check (28 September 2026). |
Pay gap reporting required before the Directive
Report on equality and equal pay
| Who reports | Employers with 500+ employees required to prepare a management report |
|---|---|
| How often | Every five years (collective agreement employers) or every three years (others) |
| What is reported | Measures to promote equality and equal pay, and headcount by gender |
| Published or internal | Public. Annexed to the management report |
| Legal basis | Pay Transparency Act 2017 (EntgTranspG), sections 21 and 22 |
When Directive (Article 9) pay gap reporting starts
Article 9 reporting covers seven indicators: the mean and median gender pay gap, the mean and median gap in variable pay, the proportion of women and men receiving variable pay, the proportion of women and men in each pay quartile, and the gender pay gap by category of workers.
Not yet legislated.
Things to work on now
- Priority for Germany. Keep responding to information requests under the 2017 Act (200+ employees).
- Priority for Germany. German courts increasingly read existing equal pay law in light of the Directive. Treat the Directive's standards as the benchmark in pay disputes.
- Use the Directive as your baseline. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted.
- Job architecture. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4).
- Data readiness. Check your HR and payroll systems can produce the Article 9 indicators, including variable pay and gaps by category of workers.
- Contracts and recruitment. Review pay secrecy clauses and pay history questions now, as these changes carry little cost.
- Review date. Set a date to check for a published bill, as national timelines can move quickly.
Legislative timeline
- November 2025Expert commission reports recommendations
- June 2026Planned cabinet decision postponed
- 7 June 2026Transposition deadline missed
Frequently asked questions
Has Germany transposed the EU Pay Transparency Directive?
At last check, Germany had not published an official draft bill. Cabinet approval of amendments to the Pay Transparency Act (Entgelttransparenzgesetz) was postponed from June 2026. The existing 2017 Act continues to apply.
When does gender pay gap reporting start in Germany?
Some reporting already applies under national law: employers with 500+ employees that must prepare a management report publish a report on equality and equal pay. Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Germany.
What should employers in Germany do now?
Keep responding to information requests under the 2017 Act (200+ employees). German courts increasingly read existing equal pay law in light of the Directive. Treat the Directive's standards as the benchmark in pay disputes. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted.