Germany’s Transparency in Wage Structures Act requires employers with 500 or more employees subject to German Commercial Code filings submit a gender pay gap report every three to five years. Organizations with 200 or more employees must provide pay data to employees upon request (Right to Information). As an EU Member State, Germany’s pay gap reporting and Right to Information obligations will be modified by the EU Pay Transparency Directive.
Germany Gender Pay Gap Reporting: What You Need to Know
LAST MODIFIED: January 10, 2025
At a glance
Who:
200 employees (Right to Information); 500 employees (pay reporting)
What:
Pay Gap Report, Right to Information, EU Pay Transparency Directive
When:
Employee data (upon request once every two years); mandatory pay report, every three to five years)
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2025 gender pay gap reporting requirements in Germany
When is Germany’s gender pay gap report due?
In Germany, employers with 500+ employees that must file a management report under Sections 264 and 289 of the German Commercial Code are also required to report on gender equality and equal pay. This management report is generally prepared within three months of an employer’s financial (fiscal) year-end. Employers must include this information in the non-commercial section of the management report, under Section 289.
- Employers covered by a collective bargaining agreement must report on gender equity and equal pay every five years. The report covers qualitative measures undertaken on gender equality and pay equity over the previous five years and quantitative measures over the last calendar year.
- Employers not covered by a collective bargaining agreement must report out every three years. The report covers the qualitative measures undertaken on gender equality and pay equity over the previous three years and quantitative measures over the last calendar year.
In addition to the gender equity and equal pay report, all companies with at least 200 employees must respond to employee requests for pay information (called Right to Information). Each employee can make this request once every two years.
Who needs to report on pay gaps in Germany?
Companies with at least 500 or more employees, who are required to file a management report pursuant to Sections 264 and 289 of the German Commercial Code, are required to file a report on gender equality and equal pay.
What pay gap metrics do I need to report in Germany?
Covered employers must report on their efforts with respect to gender equality and equal pay in their management report under the German Commercial Code (Handelsgesetzbuch – HGB). The management report must include the following
- Qualitative summary:
- The measures taken by the employer to promote equality between women and men, and the impact of those measures; and
- The measures to create equal pay for women and men.
- Quantitative summary of statistics disaggregated by gender on:
- The average total number of employees;
- The average number of full-time and part-time employees; and
- Comparison with the quantitative summary provided in the employer’s previous report.
For customers using Syndio’s Global Pay Reports, we offer a thorough breakdown of the necessary data to simplify the preparation of your Germany report.
Where do I need to share the Germany pay gap report?
Employers should attach the report to the next management report pursuant to Section 289 of the German Commercial Code that is filed after the relevant reporting year. It will also be disclosed in the business register in the German Federal Gazette.
Syndio’s Global Pay Reports help you centralize and automate reporting for 48 jurisdictions across 43 countries, including Germany. Our software makes reporting easy, fast, and accurate so you can report with confidence, even as requirements change. And our services team can answer all your detailed questions — we’re experts so you don’t have to be.
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Employers in Germany and the EU Pay Transparency Directive
The EU Pay Transparency Directive will have a significant impact on Germany’s current gender pay gap reporting requirements. Companies in Germany with 100 or more employees will be required to publicly disclose and fix any unexplained gender pay gaps. Reporting timelines are as follows:
- By 7 June 2027: Companies with 150 or more employees must submit their first report using 2026 payroll data. After that, companies with 250 or more employees will report annually, while those with 150-249 employees will report every three years.
- By 7 June 2031: Companies with 100-149 employees must submit their first report using 2030 data, with subsequent reports every three years.
The thresholds in the Directive represent the minimum requirements. Germany’s government may decide to lower these employee thresholds when they incorporate the Directive into national law by June 2026. This process involves adapting the Directive to fit Germany’s legal framework, with the option to either meet or exceed the minimum standards. Implementing stricter or additional measures is known as “gold plating” the Directive.
Starting as early as 2026, additional pay transparency obligations may be introduced for EU Member States under the Directive, including in Germany. Across the EU, these obligations include requiring employers to disclose pay ranges to job applicants, prohibiting inquiries into salary history, and enforcing the Right to Information. The Right to Information allows employees to request details about their own pay and the average pay of male and female colleagues doing the same work or work of equal value to their own role.
Syndio provides a comprehensive solution for the EU Pay Transparency Directive with everything you need to plan, prepare, and comply. Learn more ->
How Syndio helps with global pay equity, pay reporting, and pay transparency
Syndio provides the technology and expert partnership you need to comply with the growing pay equity, pay reporting, and pay transparency demands around the globe.
- Report your pay data and pay gaps — with Syndio’s Global Pay Reports. Our software supports fast, easy, and accurate compliance with pay reporting in 48 jurisdictions across 43 countries, including Germany and for the EU Pay Transparency Directive. Syndio also supports the EU’s CSRD reporting.
- Identify, explain, and fix pay gaps — with Syndio’s PayEQ and OppEQ. Our suite of solutions give you the tools and legally compliant methodologies to analyze, explain, and make progress to close pay and career advancement gaps.
- Keep your pay gaps closed — with Syndio’s Pay Finder. On-demand pay recommendations help managers and recruiters make equitable, explainable pay decisions that don’t exacerbate pay gaps.
- Create a customized action plan — with Syndio’s EU Readiness Strategy Package. Syndio’s team of experts help you build a custom strategy and support project management. This includes a change management strategy session for senior leaders, communications strategy session on pay gap and Right to Information, and ongoing support on best practices and trends.
- Craft tailored communications strategies — with Syndio’s Communications Package. Leverage best practices to build a communications plan that builds your brand while aligning to your values and objectives.
Syndio takes data privacy and security seriously. Syndio is GDPR compliant, SOC 2 Type II and ISO 27001 2022 certified, and has completed the Cloud Security Alliance CAIQv.4.02 security self-assessment for STAR Level One. Learn more in our Trust Center under “Security Reports.”
FAQ: The most asked questions about Germany’s gender pay gap reporting
Syndio helps customers all over the world with their global pay reporting needs. Here are some common questions we get about the reporting requirements under Germany’s pay gap law.
The information provided on this resource does not and is not intended to be legal advice. All information, content, and materials are provided for general informational purposes only. The links to third-party or government websites are offered for the convenience of the reader; Syndio is not responsible for the contents on linked pages.
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