The German Commission for the Implementation of the Pay Transparency Directive publishes final report on pay transparency directive implementation

At a glance

• The German Commission for the implementation of the Pay Transparency Directive (Commission) has published its final report on implementing the EU Gender Pay Transparency Directive.
• Employers bound by or applying collective bargaining agreements must still justify pay differences as gender-neutral and objective.
• Companies with 100+ employees will need to prepare pay transparency reports based on actual salaries, including allowances and regular components.
• Employees gain a right to information on individual and average pay, supported by a two-stage remedial process to address inequalities.
• The report recommends practical measures such as extended deadlines, automated calculations, and opening clauses to reduce bureaucracy.

The Federal government appointed a Commission to present recommendations on how to implement the EU Pay Transparency Directive in a lean-bureaucracy manner. The Commission has now released its final report, setting out recommendations for how the law should be transposed and what businesses should prepare for.

Key takeaways for employers

• Collective agreements do not guarantee compliance: Even where pay is set under collective bargaining, employers must demonstrate that differences are objectively justified and gender neutral. Pay groups agreed collectively will still need to meet EU standards for equal treatment.

• Reporting requirements: Companies with 100 or more employees will be obliged to publish regular pay transparency reports based on actual salaries paid, including allowances and recurring benefits. Automated reporting tools are encouraged to reduce complexity.
• Employee rights strengthened: Workers will gain access to detailed pay information, including their own salary, the average pay for comparable roles, and the criteria behind pay decisions. Where gaps are identified, a structured two-step process will apply to correct them.
• Practical measures proposed: Extended deadlines for employers under collective agreements, simplified reporting for variable pay, and exemptions for minor benefits aim to keep compliance manageable.

Although the report is advisory rather than binding, it signals the direction of the legislative draft expected in early 2026. Businesses should act now to review pay structures, adopt gender-neutral evaluation methods, and prepare systems for transparency and reporting obligations.