Germany: transposition of the EU Pay Transparency Directive is overdue
Directive (EU) 2023/970 required pay-transparency and gender-pay-gap-reporting rules to be in German law by 7 June 2026 (pre-interview pay ranges, a ban on asking salary history, workers' right to average pay information, and gender pay-gap reporting for 150+ staff). Germany missed this deadline; the existing 2017 Entgelttransparenzgesetz remains in force in its unreformed, weaker form (only a right to request comparative pay information in companies with 200+ staff) until a reform act is passed.
Do not wait for the German act: start building gender-neutral job categories and pay bands now, since the EU directive's substantive obligations will apply once Germany transposes (expected during 2026-2027). Track BMBFSFJ announcements for the Referentenentwurf and Bundestag timeline.