Germany will not implement the Pay Transparency Directive to address the gender pay gap within the specified timeframe. Member states were supposed to transpose the EU law, which was adopted in 2023, into national law by June 7. According to the current schedule, the draft from the German Federal Ministry for Family Affairs, Senior Citizens, Women and Youth (BMBFSFJ) is not expected to be approved by the cabinet until the end of June. Originally, the ministry intended to initiate the legislative process in early 2026.
One hurdle is a disagreement between trade unions and business associations. Officially, they share the same goal: equal pay for work of equal value, as stated in the Pay Transparency Directive. The gender pay gap still stands at 16% – in 2025, men earned an average gross hourly wage of €27.05, while women earned €22.81.
However, their opinions diverge when it comes to implementation. If the Confederation of German Employers’ Associations had its way, the directive would be suspended. It needs to be revised, said CEO Steffen Kampeter in an interview with Table.Briefings. In its current form, he argued, it creates no serious added value, but instead generates bureaucracy due to reporting and audit requirements.
Elke Hannack, Vice Chair of the German Trade Union Confederation sees it differently. According to Hannack, the directive has the potential to finally enforce equal pay, something the German Pay Transparency Act of 2017 failed to achieve. Kampeter and Hannack were both members of a BMBFSFJ committee tasked with implementing the directive with a minimum of bureaucracy. The committee presented its report at the end of 2025, but a consensus has yet to be reached.
When asked, the BMBFSFJ stated that the consistent enforcement of equal pay is “also a question of what is economically reasonable.” Early coordination on the law is already underway – with the stated goal of minimizing the burden on the economy.
The Pay Transparency Directive requires organizations with at least 100 employees to submit regular reports on internal pay gaps. Member states may, however, opt for a lower threshold. In addition, employees will have the right to access information on their individual earnings and the average salary of colleagues performing the same or equivalent work, regardless of company size.
Employees in Germany already have the right to some information about salaries within their company. However, this right is much more limited than what is now provided for in the EU directive. Okan Bellikli