German implementation of the EU Gender Pay Transparency Directive: Legislation not expected before 2027

At a glance

• Germany has not met the 7 June 2026 deadline for transposing the EU Gender Pay Transparency Directive (Directive). A draft bill, originally expected in early 2026, has still not been published. The competent ministry has announced that the legislation will enter into force in early 2027 at the earliest.
• Even once the legislation is in force, central employer-facing obligations will not bite immediately. The ministry has confirmed that pay reporting duties and the individual right to pay information will not become effective until June 2028.
• The Directive already has legal consequences: Public-sector employers may face direct vertical effect, and German courts are required to interpret existing national law in light of the Directive.
• Private-sector employers are not directly bound by the unimplemented Directive. However, they should be aware that the interpretive obligation on courts could lead to a gradual shift in case law even now, ahead of formal transposition.