Deloitte Legal Update 09/2026 – Update on EUPTD, Equal Pay and Pay Transparency – June 2026: Status report, current developments and measures for implementing the EUPTD

The Pay Transparency Directive (2023/970/EU, EUPTD) entered into force on 7 June 2023.

The EUPTD will lead to a comprehensive revision of the German Pay Transparency Act. The national transposition of the EUPTD into German law, scheduled by the EU legislator for 7 June 2026, is still pending.

The current Federal Cabinet will address the draft implementing legislation for the first time at its meeting on 27 May 2026. It is expected that the draft will be published around the time of this Federal Cabinet meeting.

Numerous employers with (statutory) seats in Germany are already intensively addressing the forthcoming requirements, particularly in view of the implementation deadline expiring on 7 June 2026. In addition to establishing and/or updating existing remuneration structures, job evaluation systems and pay gap analyses, many have already carried out an analysis of the (expected) addressees of employees’ entitlement to information on pay pursuant to Articles 5 et seq. EUPTD, as well as the reporting obligations under Article 9 EUPTD.

In our webcast, we will provide a concise update on these developments (including a presentation of the draft implementing act, if published by the time of the webcast) and will also discuss the legal framework applicable in practice in the period between the expiry of the implementation deadline (7 June 2026) and the entry into force of the German implementing legislation.

Key topics include:

• (In principle no) Direct applicability of the EUPTD in German law as of 7 June 2026 due to its delayed implementation, and interpretation of the German Pay Transparency Act in conformity with the Directive
• What is "fair" pay? Job evaluation criteria and insights from remuneration research
• Definition of remuneration, remuneration components and remuneration assessment for the right to pay information: implications for further implementation

Our experts Dr. Lars Hinrichs, Klaus Heeke and Elisa Ultsch, attorneys at Deloitte Legal, will guide you through the webcast. We are particularly pleased to welcome practical insights on remuneration by Dr. Daniela Eisele Wijnbergen, Professor of Human Resource Management at HSBA Hamburg School of Business Administration.

You are welcome to submit your questions for the Q&A session already as part of your registration.

We look forward to welcoming you on 03 June 2026!

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