Blogserie
Pay Transparency: Between Fair Pay and Bureaucratic Hurdles
The European Union has taken up the fight against the gender pay gap with its new Pay Transparency Directive. An important and legitimate objective – though one that poses significant challenges for businesses
Pay equity is becoming both a legal obligation and a competitive advantage.
Pre-employment transparency, mandatory disclosures during ongoing employment, new reporting obligations, and looming sanctions: The Pay Transparency Directive places considerable demands on businesses. Yet, it also presents an opportunity to rethink pay structures – making them fairer, free from discrimination – for the long term.
Employers who take early, proactive steps not only minimise legal risks, but also position themselves as modern and responsible employers. Fair and transparent pay is increasingly becoming a decisive factor in the competition for talent – especially in times of skills shortages and growing emphasis on values.
This blog series examines the legal foundations that are becoming increasingly relevant, sets out the applicable transparency and reporting requirements, and identifies where the legal risks for employers lie. We shed light on how a discrimination-free remuneration system could be structured, which data protection rules apply, and where further steps may be necessary to ensure compliance.
We will guide you towards greater pay transparency and equity and assist you with any legal questions you may have along the way.
Posts Published in this Blog Series

Lisa-Lorraine Christ, LL.M.

Pay Transparency Directive: Gender-Neutral and Objective Pay Systems – Fair Pay Based on Transparent Criteria
In our next post in this blog series: Equal pay and pay transparency will be the focus of our next post, where we examine another key element of the Pay Transparency Directive (Directive (EU) 2023/970 of 10 May 2023, hereinafter “the Directive”) – shedding light on the new standards for fair and transparent pay systems.

Dr. David Sundermann

Sanctions and measures in the event of Pay Transparency Directive violations
The EU Pay Transparency Directive (Directive (EU) 2023/970, hereinafter “EUPTD”) obliges companies to establish and secure pay equality between women and men.
While the transposition into German law has not yet been completed, it is evident that: The European legislator is taking decisive action and has assembled a comprehensive package of measures aimed at providing public institutions and workers with the instruments required to push or dare force companies toward enforcing pay equality.

Luca Borowski, LL.M.

The Pay Transparency Directive – Rights to Information and Pay Gap Reporting Duties
Following the second post in our Equal Pay and Pay Transparency blog series, which discussed recruitment obligations and workplace transparency under the EU Pay Transparency Directive, this post turns to two further elements of the Directive that are likely to have a significant medium-term impact on human resources and pay practices: Employees’ Rights to Information and Employers’ Reporting Obligations. Employees’ Rights to Information and Employers’ Reporting Obligations.

Lisa-Lorraine Christ, LL.M.

Transparency from the Outset – Employer Obligations During the Application Stage and throughout the Employment Relationship
The EU Pay Transparency Directive (EUPTD) introduces new obligations for employers to ensure pay transparency during the application stage and throughout the employment relationship. Employers will be required to provide clear information on pay, including objective criteria used to determine pay levels and progression – both during the application stage and throughout the employment relationship.

Dr. Thomas Köllmann

Pay Transparency Directive – The Countdown Is On
Equal pay for equal work or work of equal value has long been a key policy goal – yet implementing it in practice remains a challenge. The EU Pay Transparency Directive (EUPTD) is intended to strengthen the enforcement of this objective.
For employers, the Directive means increased transparency, expanded obligations, and the need to review and adjust internal pay structures in line with the new requirements.