At a Glance

• A German Commission has released a set of recommendations for transposing the EU Pay Transparency Directive into German law.
• The Federal Ministry for Education, Family Affairs, Senior Citizens, Women and Youth will develop a draft legislative bill based on these recommendations.
• Although it is not guaranteed every suggestion will become law, the Commission’s report provides employers with insight into many changes to come.

Germany has taken the next step on the path to fully implement the EU Pay Transparency Directive (PTD). This past summer, an Expert Commission on the “Low-Bureaucracy Implementation of the Pay Transparency Directive” (Commission) formed to prepare a proposal on how to transpose the PTD into German law. The Commission made its final report public on November 7, 2025.

This report is NOT a draft legislative bill but rather an expert report to legislators with recommendations and suggestions on how to transpose the PTD into German law. Overall, the Commission recommends staying very close to the base level of compliance with the PTD, as opposed to going above and beyond its requirements. However, the Commission recognizes the need to add many detailed regulations to the existing German Pay Transparency Act to implement the base level of compliance the PTD requires. The report serves as an essential resource for legislators as they prepare an initial legislative bill. Therefore, employers can use the report to glean insight into German...

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