Politicians have not done their homework. Not yet. To date, there is no draft for the Pay Transparency Act, let alone the law itself. “The EU Pay Transparency Directive will be implemented into national law during this legislative period. The legislative process will be initiated shortly.” This was announced by the Federal Ministry for Education, Family, Senior Citizens, Women and Youth a few days ago.
Companies react very differently to the missing law or its draft. According to their own statements, the majority are already well prepared for the new transparency that will inevitably come, or have set out to be well prepared.
Reporting obligations and reversal of the burden of proof: Key data are clear
But every tenth company – at least that was the result of an anonymous Mentimeter survey in our Total Rewards practical forum – is waiting. According to the motto “Where there is no plaintiff, there is no judge.” No one wanted to comment on why they were waiting.
But is this attitude smart? No! The key data for the new pay transparency are crystal clear on the table. There will be reporting requirements, more transparency in the application process, a reversal of the burden of proof, a ban on questions about previous wages and much more. The details are still missing, but there are hardly any big surprises from the legislature.
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The final report of the expert commission on the low-bureaucracy implementation of the Pay Transparency Directive also shows a clear direction. And this at least serves as the basis for the coming legislative process, although the ministry will still carry out the specific design.
Anyone who has still not started on the path towards pay transparency and equal pay is ultimately harming themselves. Because they are likely to get into a tailspin at the latest when employees make use of their new rights or they have to report – then under great time pressure.

Kirstin Grundel deals with the topics of compensation & benefits, remuneration and company pension schemes. She also works as an editor for the magazine “Comp & Ben”. She is the editorial contact for the Total Rewards practice forum.









