Germany has failed to implement the European Union's Pay Transparency Directive by the required deadline — and the country's own Federal Minister of Family Affairs, Karin Prien (CDU), has added fuel to the fire by publicly criticising the EU policy itself. For expats and international professionals working in Germany, this is more than a political story. Salary transparency laws would have given employees — including foreign nationals who often have less knowledge of local wage norms — the legal right to access information about pay structures at their workplace and to challenge potential discrimination. The delay means those rights are not yet a reality in Germany.
The EU Pay Transparency Directive, adopted in 2023, requires all EU member states to introduce a set of binding measures aimed at closing the gender pay gap and making wage-setting more open. Key provisions include the right for job applicants to receive salary information before interviews, the right for employees to request data on average pay levels for comparable roles within their company, and mandatory pay gap reporting for larger employers.
Member states were given a deadline to transpose these rules into national law. Germany has missed that deadline, meaning the protections exist on paper at EU level but cannot yet be enforced by workers in German courts or workplaces. The European Commission can take infringement proceedings against member states that fail to implement EU directives on time.
Rather than pushing to accelerate implementation, Family Minister Karin Prien (CDU) has taken a critical stance toward the directive itself, questioning the approach of using transparency as a tool to address the pay gap. This signals that the current government may not be in a hurry to push the legislation through, and that the political will to implement it swiftly is limited — at least within the CDU-led coalition.
This matters for expats because it indicates that salary transparency protections are unlikely to arrive in Germany in the short term. Workers who were hoping to use new legal tools to compare their wages or raise concerns about unequal pay will need to continue relying on the existing — and more limited — framework under Germany's current Entgelttransparenzgesetz (Pay Transparency Act), which came into force in 2017 but has been widely criticised as weak and difficult to use in practice.
Under the current German Pay Transparency Act, employees at companies with more than 200 workers have the right to request information about the average pay of colleagues doing comparable work — but only in the form of a median figure, and only if at least six employees of the opposite gender are doing similar roles. The process is cumbersome, enforcement is weak, and many workers simply do not know the right exists.
For expats, there are added layers of complexity. If you are new to the German job market, you may not have the professional network to gauge whether your salary is competitive or fair. Recruiters and employers are not currently required to state a salary range in job postings — though some do voluntarily. The absence of stronger transparency rules means negotiating a fair wage in Germany still relies heavily on individual research and negotiation skills.
Germany will eventually have to implement the EU directive, as failure to do so exposes the country to EU infringement proceedings and reputational pressure. However, given the current political climate, full implementation could take several more years. Expats who are affected by wage inequality or who simply want more visibility into pay structures at their workplace should monitor developments and consider consulting a labour law specialist (Fachanwalt für Arbeitsrecht) if they believe they are being underpaid.
Under the current Entgelttransparenzgesetz, if your company has more than 200 employees, you can formally request the median pay for a comparable group of at least six employees of the opposite gender. This is a limited right and does not give you access to individual salaries. The process is bureaucratic and rarely used. The EU directive, once implemented, would significantly expand these rights.
The gender pay gap — and more broadly, pay inequality — affects all workers in Germany regardless of nationality. Expats, especially those who are newer to the market and less familiar with local salary norms, can be particularly vulnerable to being underpaid. Using salary benchmarking tools (such as those provided by the Bundesagentur für Arbeit, Glassdoor, or Gehalt.de) is a practical way to check whether your compensation is in line with the market.
Start by researching salary benchmarks for your role, sector and region using reputable sources. If you believe you are being discriminated against based on gender or other protected characteristics, you can contact the Antidiskriminierungsstelle des Bundes (Federal Anti-Discrimination Agency) for free advice. For employment law issues, a Fachanwalt für Arbeitsrecht can assess your specific situation. Always keep records of your employment contract, any pay communications, and your job description.
Germany's failure to implement the EU Pay Transparency Directive is a setback for workers' rights — and expats are among those who stand to benefit most from stronger salary transparency rules. For now, use the tools that do exist: research salary benchmarks, ask questions during job negotiations, and be aware of your limited rights under current law. Watch for updates on the directive's implementation, and do not hesitate to seek professional advice if you feel your pay is unfair.
Source: iamexpat
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