Pay Equity Self-Assessment
Are you ready for the EU Pay Transparency Directive (2023/970)? Eight questions, instant score, individual action plan. About three minutes — as of 17 August 2026.
8 questions · reading time ~3 min · instant scoring · no sign-up · cookieless · no data transfer, evaluated locally in your browser
Practitioner note: This self-assessment is an orientation tool, not legal advice. We are compliance specialists, not a law firm. Pay-gap analysis methodology, joint pay assessment proceedings (Art. 10 Directive 2023/970) and the burden-of-proof rule in § 22 AGG require an individual legal review. The Directive does not bind employers directly — it takes effect through national transposing law. The transposition deadline of 7 June 2026 has expired; as at 17 August 2026 neither Germany (BT-Drs. 21/7026 of 8 July 2026: not even a ministerial draft) nor Austria had a transposing act in place.
Sources
- Directive (EU) 2023/970 — Pay Transparency (of 10 May 2023; transposition deadline 7 June 2026 under Art. 34(1), expired without transposition in Germany and Austria) — reporting: ≥ 250 employees by 7 June 2027 and yearly thereafter (Art. 9(2)), 150-249 by 7 June 2027 and then every 3 years (Art. 9(3)), 100-149 by 7 June 2031 and then every 3 years (Art. 9(4)), below 100 no obligation unless Member States provide for one (Art. 9(5)); joint pay assessment trigger: at least 5 % unjustified gap (Art. 10)
- Pay Transparency Act (EntgTranspG) (of 30 June 2017, Federal Law Gazette I p. 2152, last amended 5 July 2021) — individual right to information in establishments with, as a rule, more than 200 employees (§§ 10-12)
- General Equal Treatment Act (AGG) (of 14 August 2006, amended) — § 15 compensation and damages (no administrative fine), § 22 burden of proof
- BAG 8 AZR 488/19 — pay below the median reference pay disclosed under §§ 10 ff. EntgTranspG regularly creates a rebuttable presumption of gender-based pay discrimination (Art. 157 TFEU, § 3(1), § 7 EntgTranspG)