Knowledge
The EU Pay Transparency Directive 2023/970
Directive (EU) 2023/970 obliges companies to be more transparent about their pay structures. For mid-sized companies this means: traceable pay differences, documented criteria and robust comparator groups. Here you will find a clear overview of the obligations, deadlines and the question of when your company is affected.
What the directive means in practice
The burden of proof has shifted
Since June 2026, German courts have aligned their interpretation of the Pay Transparency Act with the EU Pay Transparency Directive. When pay differences are questioned, transparent analyses and documented decision-making become significantly more important. Creating transparency early provides certainty and a solid basis for sound decisions.
The 5% threshold deserves attention
If a comparator group shows a pay gap of 5% or more that cannot be objectively justified, further reviews may become necessary. Creating transparency early reduces risks and provides certainty for future decisions.
Excel delivers numbers. AIHRCON delivers clarity.
Excel analyses are laborious and error-prone. Consulting projects cost time and budget. Pure software delivers metrics but does not answer the decisive questions. AIHRCON combines artificial intelligence, HR expertise and a documented methodology into an audit-ready pay audit. The result: clear, verifiable and ready for practice.
The key deadlines at a glance
June 2023
The EU Pay Transparency Directive (EU) 2023/970 enters into force.
June 2026
Deadline for transposition into national law. In Germany, the implementing act is currently still pending.
From 2027
Expected start of the reporting obligations, staggered by company size.
Already today
German courts already align their interpretation with the directive. Creating transparency early provides certainty.
Impact check by company size
| Company size | Reporting obligation | Documentation requirements |
|---|---|---|
| 250+ employees | annually | high |
| 150–249 employees | every 3 years | high |
| 100–149 employees | every 3 years | increasingly relevant |
| under 100 employees | currently no reporting obligation | recommended |
As of August 2026, based on Directive (EU) 2023/970; the German implementing act is still pending
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