The implementation of the Pay Transparency Directive (Directive 2023/970/EU, EUPTD) into German law is still pending, with a first draft of the national implementation act expected in the fourth quarter of 2025. Employers with their registered office in Germany who are already working on implementing of the EUPTD into domestic law have, in recent months, established and/or updated remuneration structures and pay gap analyses and, among other things, analysed the (expected) recipients of individual employees' right to information on remuneration in accordance with Art. 5 et seq. EUPTD and the reporting obligations under Art. 9 EUPTD. This is particularly noteworthy for international groups of companies with group companies and/or branches in EEA countries and in non-EEA countries.

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