Pay Transparency from 2026

By June 7, 2026, the EU Pay Transparency Directive must be transposed into national law and aligned with the Pay Transparency Act, which has been in force since 2017. The main objectives are to prevent gender-based pay discrimination and to promote salary transparency.

The current law applies to companies with 200 or more employees. Companies with 500 or more employees are required to report on pay equality. Gender-specific pay gaps are to be identified and eliminated, and pay structures analyzed.

Courts have already granted female employees the right to equal pay for equal or equivalent work under the existing legal framework. In one case, a court awarded a higher salary to a female employee who invoked the Pay Transparency Act because her male counterparts received higher pay. The employer had failed to adequately demonstrate and prove how criteria such as professional experience, length of service, and work quality were assessed and weighted to ensure compliance with the principle of equal pay.

In companies with 200 or more employees, employees have the right to request information on the average pay of a comparison group of at least six people performing the same or equivalent work. Companies with 500 or more employees must additionally analyze and report whether pay equality exists within the organization. The report must be broken down by gender and include both full-time and part-time positions.

Under the EU Directive, an individual right to information on comparative pay will apply in all companies, regardless of size. The information must be provided within two months of the request.

Companies with 100 or more employees will also be required to report on pay equality, starting from June 7, 2031, every three years.For companies with 150 to 249 employees, this obligation begins in 2027, and for those with 250 or more employees, it will apply annually from 2027.Companies with 50 or more employees must disclose the starting salary and its range before the recruitment process begins. The reference point for all reporting is always the previous year. It is still unclear whether employers will also have to provide information on pay criteria under national law. Applicants may no longer be asked about their previous salary.

Number of Employees	Right to Information for Employees & Applicants	Obligation to Disclose Pay Criteria	Gender Pay Gap Reporting Requirement
< 50	from 2026	?	–
51–99	from 2026	from 2026	–
100–149	from 2026	from 2026	from 2031 (every 3 years)
150–249	from 2026	from 2026	from 2027 (every 3 years)
250–499	from 2026	from 2026	from 2027 (annually)
> 500	from 2026	from 2026	from 2027 (annually)

Companies without collective bargaining agreements should start implementing a transparent and objective remuneration system that is easy to understand and trace. Existing pay gaps must be identified and rectified.

All companies, regardless of size, will be affected by the new pay transparency rules by June 7, 2026 at the latest. Even small businesses will be required to grant at least a right to information to employees and applicants.

It is therefore strongly recommended that companies review their pay structures and prepare for information requests in advance.