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Pay Transparency: When You Can Request a Comparison Salary

Directive (EU) 2023/970 had to be implemented by June 2026. Whether and when you can request a comparison salary depends on a German law that the sources reviewed do not yet confirm.
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Contents

Asking for a comparison salary sounds like a simple right, but in Germany it is not yet set out in statute. The EU pay transparency directive requires implementation, and that is exactly where the question lies: when can you actually demand information? This guide explains the current position and what you can do in the meantime.

Short answer: Directive (EU) 2023/970 had to be implemented in national law by 7 June 2026. A Bundestag briefing dated 10 July 2026 names no referee draft and no government bill with a date for Germany. A statutory right to information on comparison pay from a fixed date therefore cannot be derived from the sources. The most recent documented status is 8 September 2026; after that date, check the position with the responsible federal ministry. Last updated: November 2026.

The most important points in brief

  • Directive (EU) 2023/970 aims to strengthen equal pay for equal work or work of equal value through transparency.
  • The deadline for implementation into national law was 7 June 2026.
  • According to the Bundestag briefing of 10 July 2026, no dated law existed at that point, only preparatory work and proposals.
  • A right to information on comparison pay is therefore not confirmed as a fixed right for you today.
  • Until a law is passed, collective agreements, job adverts and a well-prepared salary negotiation are the most useful tools.

What does the EU directive regulate?

Directive (EU) 2023/970 pursues the goal of enforcing equal pay for women and men for equal work or work of equal value. Among other things, it contains rules on pay transparency, which are meant to give employees a clearer view of pay structures. The directive is published in the Official Journal of the European Union and is addressed to the Member States, not directly to individual employers.

For you, this means that the directive sets the framework, while the concrete design rests with the German legislator. Details on thresholds, deadlines and procedures decide how strong your right would be in practice. In the sources reviewed, those details are not yet fixed for Germany.

Why is the current status unclear?

According to the Bundestag briefing of 10 July 2026, no referee draft or government bill with a date had been presented at that point. The briefing points to the coalition agreement of the 21st electoral term, which provides for implementation in a low-bureaucracy way, and to an expert commission whose final report was presented on 24 October 2025. Associations had also submitted proposals to the lobbying register. On 8 July 2026 the federal government answered (Bundestag printed paper 21/7026) that the responsible ministry had prepared a draft and was still clarifying individual questions, and that the legislative procedure was to be started afterwards. On 8 September 2026 the Left Party parliamentary group tabled a motion (printed paper 21/7916) asking the federal government to present a draft bill.

The timeline explains why this guide relies on verified dates. The deadline, preparatory work and closing dates are documented. A law with fixed rules is not.

Which milestones are documented?

DateEventSource
17 May 2023Directive (EU) 2023/970 published in the Official JournalEUR-Lex
24 October 2025Final report of the expert commission set up by the Federal Ministry for Education, Family, Seniors, Women and YouthBundestag, briefing EU 6
7 June 2026Deadline for implementation into national lawBundestag, briefing EU 6
8 June 2026Briefing by the Bundestag research unit on the commission’s proposalsBundestag, briefing EU 6
8 July 2026Federal government answer to a parliamentary inquiry: draft prepared, procedure not yet startedBundestag, printed paper 21/7026
10 July 2026Closing date of the briefing on implementation options and data protectionBundestag, briefing EU 6
8 September 2026Motion of the Left Party group asking the government to present a draft billBundestag, printed paper 21/7916

The table summarises documented data only. For the current legislative status, check the responsible federal ministry, because procedures can move quickly.

What can you do until a law is passed?

Even without a statutory right, you can prepare your salary well. The most important lever is classifying your own work. If you describe your tasks concretely and compare them with job descriptions, you can argue factually in the conversation.

Collective agreements are a reliable primary source if your employer is bound by one. They set pay groups and steps. Without such a binding, classification relies on the job advert and your own profile. The guide on applying for your first job (in German) shows how to approach the conversation.

Which reliable pay information can you use?

Not every number you find online helps in a negotiation. The value of a figure depends on who published it and how it was produced. The overview below helps you classify the sources.

SourceWhat it tells youLimitation
Collective agreementBinding pay rules for bound employersApplies only if the employer is bound or the contract refers to it
Job advertThe employer’s stated pay for a specific roleNot a guarantee, the negotiation remains open
Official statisticsAverage values for groups and sectorsNo statement about your role in the company
Online salary portalsSelf-reported figures from usersNot verified, often incomplete

When you compare, check whether full-time or part-time work, professional experience and responsibility match. A comparison with a role that has different tasks can easily mislead.

What can you check in your employment contract today?

Regardless of the law, a close look at your employment contract is worthwhile. Many questions about pay can be clarified there before problems arise later.

  • Is the basic salary shown separately from variable components, allowances and special payments?
  • Does the contract refer to a collective agreement or pay group, and is that understandable to you?
  • Are working hours and pay described so that you can assess overtime?
  • Is there a rule on adjusting pay after the probation period or after a fixed time?

Anyone who fully understands the contract can ask more precise questions later. This matters especially for graduates who have their first salary negotiation ahead.

What should a salary conversation include?

A good salary conversation begins with your performance and ends with a concrete figure or a clear question. Whether a comparison with colleagues in your company is possible depends on the employer’s openness. Ask factually and without accusation.

Which questions should you ask yourself?

Before you negotiate or accept an offer, a short check helps. These questions give orientation:

  • Is the employer bound by a collective agreement, and which pay group fits my role?
  • Which tasks do comparable employees carry out in the company, as far as I can learn that?
  • Is there a works council that can answer questions about pay?
  • Is my salary written into the contract, including all components and allowances?

Frequently asked questions

Can I request my comparison salary today?

Under the sources reviewed, a statutory right to information derived from the directive is not established as current German law. You can still ask. Whether the employer answers depends on company culture and the working climate.

Would a future right also apply to small companies?

Whether and from what company size a right would apply is not fixed in the sources reviewed. That question depends on the future German law, so check the text once it has been passed.

Must the salary appear in the job advert?

The directive contains transparency rules. How that applies to job adverts depends on the German implementing law. Without a statutory requirement, the employer decides what the advert states.

What if my employer does not answer my question?

You can still prepare your negotiation through your own performance and your tasks. Write down the conversation so you can refer back to it later. If you are unsure, the works council or a specialist in employment law can advise you.

What to do now

  1. Check whether your employer is bound by a collective agreement and which pay group could apply.
  2. Describe your tasks concretely and compare them with job descriptions.
  3. Follow the legislative status with the responsible ministry before you rely on any right.
  4. Prepare the salary conversation with a clear figure and your arguments.

Related guides

Sources: German Bundestag, research unit EU 6, questions on Directive (EU) 2023/970 (status 10 July 2026, in German); Directive (EU) 2023/970 on pay transparency, EUR-Lex (accessed November 2026); Bundestag printed paper 21/7026 (answer of the federal government, 8 July 2026, in German); Bundestag printed paper 21/7916 (motion of the Left Party group, 8 September 2026, accessed 2 November 2026, in German).

Last updated: November 2026. This guide is general information, not individual advice.

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