Focus on the EU Pay Transparency Directive
Many companies are currently exempt from the reporting obligation under the German Pay Transparency Act, as it only applies to employers with more than 500 employees. However, the EU Pay Transparency Directive, which comes into force on June 7, 2026, successively obliges all private and public companies with 100 or more employees to promote gender equality in pay.
The key requirements of the Directive include
Companies must provide applicants with salary ranges for advertised positions and ensure that the recruitment process is gender-neutral and non-discriminatory. Inquiries about applicants' previous salary data are not permitted.
Employers are obliged to communicate clear remuneration policies and provide employees with information on their salary and any gender pay gap on request. In addition, open discussions about salary should be made possible without restrictions.
Companies with 150+ employees must submit regular reports on gender-specific pay gaps and the distribution of remuneration from 2027 and those with 100+ employees from 2031.
If there are unjustified wage differences of more than 5%, companies are obliged to carry out an analysis together with employee representatives and take corrective measures.
Companies must provide full compensation for pay inequality and expect sanctions in the event of non-compliance. Employees are also protected from reprisals if they demand their rights.
By implementing these requirements in good time, companies not only comply with legal requirements, but also promote a fairer and more transparent corporate culture.
In order to be one step ahead of the requirements of the EU Pay Transparency Directive, you should take the following dates and recommendations into account when reviewing your operational processes:
Our experience shows that pre-audits are a decisive lever for successfully mastering the transition to the new EU Pay Transparency regulations. A structured analysis - from the segregation of roles, genders and salary data to the review of gender-specific remuneration differences - not only ensures current compliance, but also prepares you specifically for future requirements.
The required data on gender-specific pay gaps is identified at an early stage and can be recorded in a structured manner. This helps you to comply with any reporting obligations more easily later on.
It enables you to identify large pay gaps and develop sound strategies to compensate for them in a sustainable and fair manner. In this way, you can create long-term solutions that go beyond simple pay rises and promote true equality of opportunity - while proactively avoiding potential compensation claims or sanctions.
If a general review of your job architectures, salary ranges and remuneration structures is required, you will have sufficient time to carry this out and involve any employee representatives.
Our approach is based on both the existing German Pay Transparency Act and the forthcoming EU Directive. Comprehensive information on our audit methodology can be found here. Take the opportunity to set the course now!
Comprehensive analyses in larger units or in cross-border projects with many local units can be a considerable challenge due to the amount of data involved. To ensure that you can focus on strategic issues - such as the detailed analysis of pay gaps and the development of concrete measures to eliminate inequalities - we have developed the solution for you: Our proven Littler view system has been supplemented by an EU Gender Pay Gap Tool, which allows us to review your pay structures at a fixed price and in a very short time.
Analyze compensation data efficiently - data provided by you in Excel form can be examined at the touch of a button.
Identify risk factors - salaries that show anomalies are automatically red-flagged and highlighted for detailed review.
Visualize results - aggregated data is presented in interactive dashboards, enabling quick and informed decision making.
Fast analysis at the touch of a button - together we can focus on the difficult cases
Real-time data as a basis - all dashboards can reflect the actual status
Comparison with historical data - how has the pay gap developed?
Minimize sources of error - manual analyses are error-prone and time-consuming
Works councils' right to information on non-discriminatory pay does not apply to third-party evaluations for the time being - companies decide for themselves when to involve their employee representatives
