Pay Transparency Act 2026

More transparency from 2026: What does that mean specifically?

The previous Pay Transparency Act has been in force since 2017. The reform, which took effect on June 7, 2026, will come into force, and your position will now be significantly strengthened—both in the application process and in the ongoing employment relationship. The aim is to make remuneration structures more understandable and to identify and eliminate existing inequalities more effectively.

What is important is that this is not about disclosing individual salaries of specific people. Structured, anonymized comparative data and clear evaluation criteria are crucial. Companies are obliged to present remuneration systems in a comprehensible manner. The goal is to make structural inequalities visible at an early stage—before they spread and solidify over the years.

The three core changes

The reform brings three central innovations that are applicable to all employees and applicants are directly relevant:

• Transparent salary information in recruiting: Employers must disclose remuneration before or at the latest during the interview – as a concrete amount or as a realistic range. Job advertisements without any salary information are now a thing of the past.
• Extended individual right to information: Employees can obtain information about average salaries for comparable jobs - regardless of the size of the company. Depending on the number of employees, tiers apply duties.
• Reporting requirements for larger companies: From 100 employees Regular reports on equal pay are provided. These reports must disclose whether and to what extent gender-specific differences exist.

These measures apply across the Union and aim to address gender-specific issues to systematically reduce pay differences. For employees this specifically means: more orientation, better basis for negotiations and stronger protection against discrimination.

Your individual right to information

In the future, you will be able to find out what the average salary is in comparable positions is paid - anonymized and broken down. You can also ask which objective criteria your salary was determined and whether differences exist - in particular between men and women.

An activity is considered comparable if it is consistent in terms of responsibility, requirements, and qualification is equivalent. What matters is not the job title, but the actual job title function. Employees must be able to replace each other. That means: If as a project manager, you have the same tasks and responsibilities as a colleague with a different job title, his position is the relevant comparison group.

The information includes not only the basic salary, but also all salary components variable remuneration, bonuses, allowances, and monetary benefits such as company cars or company pension scheme. The employer must also disclose the criteria that he for the determination of remuneration and the development of remuneration. This gives employees for the first time a structured insight into the logic of the salary system.

How to make a legally secure request

A structured approach significantly increases the chances of success. Note the following steps:

• Define the comparison group based on tasks, responsibilities, and qualifications.
• If you make your request in writing or by email, you will have proof.
• Specify the information you want specifically: average wages and the criteria for determining wages.
• Set a reasonable deadline, around four weeks.
• Document your request carefully. Date, recipient, content.

You shouldn't simply accept unclear answers or blanket rejections. Stays If there is no reaction at all, legal support may be useful. That's in the future The burden of proof is greater on the employer: there will be plausible evidence for one If unequal treatment is alleged, the company does not have to prove objective reasons vice versa.

In principle, the information can be reapplied for every two years. In essential cases Changes, such as promotion to a higher salary group, a change of job or a significant company restructuring - the request can also be made earlier become. Carefully document each request and the response received; these Documents can be important evidence in a later salary dispute.

Protection against discrimination

The reform explicitly strengthens protection against reprisals. Anyone who exercises their right to information or talks about their own income should not experience any disadvantages under employment law. This applies to every form of disadvantage, from warnings to worse reviews to... termination.

Should discrimination nevertheless occur, there are legal defense options. This The law makes it easier to provide evidence: If there is a temporal or factual connection The employer must explain whether there is a difference between the request and the disadvantage prove that he treated the person worse for other reasons. Employees can claim damages and compensation.

Discussions with colleagues about salaries are also protected. Employers are not allowed to include clauses in employment contracts or instructions forbidding people to talk about their own remuneration. Clauses that contain confidentiality requirements for salaries are ineffective in this respect.

Role of the works council

The works council can help you enforce yours Support the right to information. Specifically, it can help formulate the request, address structural inequalities, communicate them to the human resources department, and monitor compliance with legal requirements.

In companies with a works council, this takes on a key function: the employee addresses his request to the works council, which then submits it to the employer makes. This detour is intended to protect the anonymity of the requester and to provide a more structured Ensure processing.

Especially if several employees have similar questions, the works council can discuss topics bundle and approach them systematically. This is often more effective than individual requests because The works council has its own information rights in accordance with the Works Constitution Act and can combine data that is not accessible to individual employees.

For employees who do not have a works council, the direct request to the employer is the only way. In this case, it is particularly important to carefully formulate the request and put it in writing. Anyone looking for support can find it here Trade unions and labor law lawyers.

When does legal advice make sense?

External support is particularly recommended in the following situations:

• Your request remains unanswered or is rejected with blanket reasons.
• The comparison group is contested by the employer.
• Criteria for determining fees are not disclosed.
• There is suspicion of discrimination, for example based on gender, origin, disability, or age.

In the future, the burden of proof will lie more heavily on the employer. Become plausible clues for unequal treatment, the company must prove objective reasons. A labor law attorney can realistically assess the chances of success and the choose the right strategy, from out-of-court settlement to judicial enforcement .

Importance for your career

Transparent remuneration structures create negotiation security in every phase Professional life:

• When starting your career You can recognize market remuneration at an early stage and negotiate more specifically.
• For transportation Do you have objective comparative values ​​that support your argument?
• After parental leave or part-time phases You can check whether your salary has been adjusted appropriately.
• For internal transfers, you gain clarity about the evaluation of the new function.

Transparency makes it easier to have objective discussions about salary development and career prospects. Anyone who can support their own position with reliable data negotiates on an equal footing. This also applies to situations in which a new employment contract is concluded, for example during an internal change or a renegotiation.

Those who return after parental or care leave are often particularly affected by creeping salary differences. While absentees do not receive any salary increases and have missed promotion rounds, colleagues in the same position may have developed significantly further. The new right to information gives those affected the possibility of making this backlog visible and, if necessary, adjusting it demand.

Particularly relevant for women

Statistically, gender-specific pay differences still exist. The reform continues right here: pay structures can be systematically checked, comparative data make argumentation easier, and employers have to objectively justify differences.

This improves, especially when returning to work after parental leave or longer part-time periods thus significantly increasing the negotiating position. The mandatory pay reports for companies with 100 or more employees are making this possible for the first time at company level to systematically understand whether and where women are structurally paid less than men in comparable positions. Employers that make a significant difference cannot justify, come under considerable pressure to act.

Pay discrimination doesn't just affect women. Factors such as origin, disability, or age can also play a role. Structured comparative data and transparent criteria make it easier to identify and check such inequalities. If you suspect discrimination in the workplace , you are entitled to further rights, including the right to equal remuneration enforced by labor courts, retroactively for up to three years.

Data protection and smaller companies

Disclosure is always anonymized. Personal salary data of individuals are not disclosed. Transparency means structural openness, not individual openness Exposure. The data protection requirements of the GDPR remain fully adhered to.

Even if certain reporting obligations only apply to certain company sizes, this remains the case the principle of equal pay for equal work or work of equal value is unrestricted valid - even in small companies. In addition, the ban on discrimination still applies according to national and European law. If there are plausible indications of disadvantage the employer must provide factual justifications.

In practice, the situation is more difficult in small businesses: the comparison group is smaller, anonymity is harder to establish, and the power imbalance between employee and employer is often more pronounced. This makes it all the more important to seek professional advice if discrimination is suspected and to get support—from a union, a labor law attorney, or the Federal Anti-Discrimination Agency.

How do you recognize fair employers? Clear information should already be included in the job advertisement be included in the starting salary or salary range. Transparency Job descriptions and open communication are further indicators of professionalism Compensation systems. A targeted question about the remuneration model in the interview signals objectivity and interest.

Checklist for 2026

Prepare for the new rights. Check the following points:

• I know my comparison group - based on tasks, responsibility, and qualifications.
• I know how to submit a request for information—in writing, with a specific description of the information required and a reasonable deadline.
• I have documented my previous compensation discussions. Date, content, result.
• I consciously check job advertisements for salary information, as an indicator of a culture of transparency.
• I speak objectively and confidently about remuneration, because discussions about one's own salary are expressly protected.

Anyone who knows their rights and uses them strategically gains clarity and security in negotiations. The reform shifts the focus from non-transparent individual decisions to comprehensible structures—more orientation for employees, for companies higher demands on transparency and, in the long term, more trust and fairness.