Ask a German HR director about pay transparency obligations and you will likely hear a confident summary of the Entgelttransparenzgesetz, the law that has governed equal pay practices since July 2017. The framework is familiar: it applies to employers with more than 200 employees, reporting obligations sit with companies above 500, and the individual right to information is exercised rarely enough that most HR teams handle requests on an ad hoc basis. For nearly a decade, that has been the operating model.
The conventional view, in other words, is that pay transparency is a known quantity. The June 7, 2026 transposition deadline for the EU Pay Transparency Directive is treated, in many planning conversations I see, as a refresh of an existing regime rather than something requiring fundamental redesign.
The evidence points the other way. Active Mind Legal characterises the directive as “a systemic change” rather than a compliance update, and the reasoning is straightforward once you look at the threshold mechanics. The current Pay Transparency Act applies only to employers with more than 200 employees; the new directive expands scope to companies with 100 or more employees. Reporting obligations, currently triggered at 500 employees, will apply at 100 under the directive, on either an annual or three-yearly basis. Active Mind Legal notes this affects “significantly more companies than before,” particularly in the mid-market segment that has never had to build the underlying data infrastructure.