Since 7 June 2026 (EUR-Lex), the deadline by which Germany was to transpose the Pay Transparency Directive (EU) 2023/970 has passed. Its Article 5 gives applicants the right to learn the initial pay for a position, or its range, before the contract is negotiated. According to the Federal Government’s answer of July 2026 (Bundestag document 21/7026), the legislative process had not yet been started at that point. So there is time, but no reason to sit still: if you derive the range now and put it in the job ad, the work is done before the transposition law arrives, and you already reach people who want to know what they are signing up for before they apply.
Where transposition stands since 7 June 2026
Article 34 of the Directive required member states to bring into force the necessary laws, regulations and administrative provisions by 7 June 2026 (EUR-Lex).
In Germany, the Pay Transparency Act (Entgelttransparenzgesetz) is the obvious place for this. The Federal Ministry for Education, Family Affairs, Senior Citizens, Women and Youth writes that the Directive requires “further developing the Pay Transparency Act” (BMBFSFJ). The current Act has been in force since 6 July 2017 (BMBFSFJ), and the published version reflects an amendment of 5 July 2021 (Gesetze im Internet). Its right to information is aimed at employees. It contains no right for applicants to learn the initial pay, and it sets no rules on this for job ads.
The Federal Government has answered questions from the Bundestag on the state of transposition twice. In January 2026 it wrote that it was working on a “low-bureaucracy 1-to-1 transposition”, and that the legislative process would be prepared once the ministerial draft was finalised (Bundestag document 21/3928). In July 2026 it said that the lead ministry had made the necessary preparations for a draft bill and was still clarifying individual questions, after which the legislative process was to be started (Bundestag document 21/7026). These answers do not show when the law will be promulgated.
What this means for private employers
For the job ad itself, the open question changes little. What Article 5 requires at a minimum is in the text of the Directive, and if you switch your ads over now, you will not have to do it under time pressure later. How to receive the application cleanly afterwards is covered in the article on accepting job applications online.
What Article 5 requires of job ads
Article 5(1) names two things that applicants are to receive from the prospective employer: first, “the initial pay or its range, based on objective, gender-neutral criteria, to be attributed for the position concerned” (EUR-Lex), and second, “where applicable, the relevant provisions of the collective agreement applied by the employer in relation to the position” (EUR-Lex). If you pay under a collective agreement, you therefore name not only an amount but also the agreement it comes from.
Such information shall be provided in a manner such as to ensure an informed and transparent negotiation on pay, such as in a published job vacancy notice, prior to the job interview or otherwise.
The published job vacancy notice is an example there, not an obligation. The yardstick is a different one: the information has to come early enough for applicants to negotiate on an informed basis. A range that only appears in the draft contract is likely to miss that yardstick. The job ad is the simplest place because it answers the question before anyone invests time in an application, and because it reads the same for everyone. Besides the information on pay, Article 5 contains three further rules that affect the recruitment process, and Article 2 sets out whom they apply to:
- No questions about previous pay. “An employer shall not ask applicants about their pay history during their current or previous employment relationships.” (Article 5(2), EUR-Lex)
- Neutral ads. Employers shall ensure “that job vacancy notices and job titles are gender-neutral” (Article 5(3), EUR-Lex).
- All sectors. “This Directive applies to employers in public and private sectors.” (Article 2(1), EUR-Lex)
- Even before the first working day. “For the purposes of Article 5, this Directive applies to applicants for employment.” (Article 2(3), EUR-Lex)
No size threshold in Article 5
Who has to do what at which size
The Directive staggers several obligations by the number of workers, and current German law has thresholds of its own. The table sets both side by side. For the job ad, only the first row matters.
Scroll table sideways
| Rule | Who is covered? | Deadline or status | Provision |
|---|---|---|---|
| Information on initial pay or its range | all employers, no size threshold | transposition by 7 June 2026 | Directive, Article 5 and Article 34 |
| Disclose criteria for pay and pay progression | all employers; for pay progression, member states may exempt employers with fewer than 50 workers | with the transposition law | Directive, Article 6 |
| Report on the pay gap | 250 workers or more | first by 7 June 2027, then every year thereafter | Directive, Article 9(2) |
| Report on the pay gap | 150 to 249 workers | by 7 June 2027, then every three years | Directive, Article 9(3) |
| Report on the pay gap | 100 to 149 workers | by 7 June 2031, then every three years | Directive, Article 9(4) |
| Report on pay | fewer than 100 workers: voluntary or under national law | no deadline in the Directive | Directive, Article 9(5) |
| Right to information for employees (current law) | establishments with, as a rule, more than 200 employees | Act in force since 6 July 2017 | Pay Transparency Act, Section 12 |
| Report on equality and equal pay (current law) | employers obliged to prepare a management report with, as a rule, more than 500 employees | Act in force since 6 July 2017 | Pay Transparency Act, Section 21 |
The limit of 50 (EUR-Lex) workers concerns pay progression only, meaning the criteria by which pay rises over time. In its final report of 24 October 2025 (BMBFSFJ), the commission on a low-bureaucracy transposition of the Pay Transparency Directive recommended exempting employers “with fewer than 50 employees” from this obligation. The same report summarises the Directive itself as containing “a right to information for job applicants about the initial pay or its range”. A right to information means: whoever asks gets the answer. If you already put the range in the ad, you have answered the question before it is asked. The thresholds of 200 and 500 (Gesetze im Internet) employees come from the current Pay Transparency Act and concern employees, not applicants.
Under 100 does not mean never
Why the range pays off today
The gender pay gap in Germany is 16 percent (BMBFSFJ). According to the ministry, even with the same formal qualifications and otherwise identical characteristics, the difference is still six percent (BMBFSFJ).
The next Equal Pay Day takes place on 27 February 2027 (BMBFSFJ). Article 5 starts where one side knows the figures and the other has to guess: at the first offer.
For the individual business, something more tangible counts. An ad without any information on pay leaves the most important question open, and anyone who wants to ask it has to apply or call first. A range sorts things out beforehand: whoever cannot live with the frame does not apply, and whoever applies knows it. The first interview then starts with the tasks, not with the question of whether the two sides can agree at all.
Better-matched applications
Anyone who knows the range decides before applying whether it fits. An interview that fails over money can be avoided that way.
A level starting point
Everyone reads the same figure. Someone who negotiates less well or does not know their own market rate does not start at a disadvantage.
A head start on the obligation
You will need the criteria and ranges you set now once the transposition law arrives anyway. If you have them, you only need to check later whether they match the wording.
The range is one building block of a careers page for skilled staff, not a substitute for it. It works best next to an honest description of the tasks and the working day. The idea is the same as for a business that shows prices on its website: a figure people can follow can build more trust than a friendly sentence without substance.
Deriving the range: three routes
Article 6(1) requires employers to make easily accessible to their workers the criteria used to determine pay, pay levels and pay progression. “Those criteria shall be objective and gender neutral.” (EUR-Lex) A range in the job ad is therefore only as good as the rule it follows from. Which rule that is depends on the business.
Route 1: the collective agreement sets the range
If you are bound by a collective agreement or apply one, most of the work is already done. The pay group of the position usually gives the lower limit, and the steps within the group give the range. The ad should state the group, the name of the collective agreement and the amount from the lowest to the highest step that is possible on entry. “Paid according to the collective agreement” alone is not enough: otherwise the applicant has to look up which group is meant and what it means in euros.
Route 2: an in-house grading
Without a collective agreement, a simple grid of your own is worthwhile. For each position you set a lower limit that applies to entry with the minimum requirements and an upper limit for entry with relevant experience. In between, the criteria you wrote down beforehand decide. What matters is that the same criteria apply to everyone who applies for the position, and that you can later explain why someone started at a particular point in the range.
Route 3: starting from the current structure
The third route starts with the people who already do the job today. What do they earn on entry, and what after a few years? If there are differences that cannot be explained by criteria, they need to be clarified first, before the figure goes into a public ad. From 100 (EUR-Lex) workers, Article 9 provides for reports on the pay gap later in any case; if you put your structure in order now, you will already have started on that work.
These criteria are suitable for justifying a range and the placement within it:
- Requirements of the position: training, degree or qualification needed for the job.
- Relevant professional experience: years in a comparable job, not age.
- Responsibility: leading people, a budget or decisions with consequences for others.
- Working conditions: shifts, weekends, physical strain or on-call duty.
- Scope: the range applies to full-time work, part-time is calculated pro rata.
What does not belong in the criteria: the applicant’s previous pay, negotiating skill in the interview and characteristics that may be indirectly linked to sex, such as a premium for a career without interruptions. Such characteristics are hard to justify as objective and gender-neutral. For the field in the ad, a fixed form works well that states the amount, the reference basis and the grounds in one go:
With a collective agreement:
[amount] to [amount] euros gross per month (full-time, [weekly hours] hours),
pay group [group] under [collective agreement], placement by professional experience.
Without a collective agreement:
[amount] to [amount] euros gross per month for full-time work ([weekly hours] hours),
entry depending on qualification and relevant experience. Part-time pro rata.
Apprenticeship:
[amount] euros in the first, [amount] euros in the second, [amount] euros in the third year of training.A “from” alone is not a range
What should be in the job ad
Some phrases sound like information on pay but are not. The table shows what you can write instead.
Scroll table sideways
| Typical phrase | Better | Why |
|---|---|---|
| “Attractive pay” | “[amount] to [amount] euros gross per month for full-time work” | An adjective is not a range and cannot be compared. |
| “Paid according to the collective agreement” | “Pay group [group] under [collective agreement], [amount] to [amount] euros” | Article 5 explicitly names the relevant provisions of the collective agreement, and the amount saves looking it up. |
| “Please state your salary expectations” | State the range and leave out the question | The Directive does not prohibit this question, but with a range in the ad it becomes unnecessary. What Article 5(2) prohibits is asking about previous pay. |
| “Pay by agreement” | State the range and add what the placement depends on | By agreement means for the applicant: negotiating without any point of reference. |
| “Salesman (m/f/d)” | “Sales specialist” or “Sales adviser” | Article 5(3) requires gender-neutral job titles. Whether the addition in brackets is enough for this will only be settled by transposition; a neutral title is the more cautious choice. |
Article 5 does not expressly settle whether there is negotiation within the range. If anything, it presupposes negotiation, since the information is meant to enable informed negotiation. Whether you negotiate remains your decision. If you do, the criteria from the previous section should determine where someone lands, not persistence in the interview. If you do not, say so in the ad, and everyone knows where they stand.
The rest of the ad follows the same rules as any other text on your website: short sentences, concrete tasks, no filler phrases. How to manage that is shown in the article on website copy customers actually read. Whether you address applicants formally or informally depends on your business; the trade-offs are covered in the article on tone of address on your website.
How pay appears on the careers page in XICflow
For open positions, XICflow has the “Job openings” block.
Each position in it has its own fields: job title, employment type, location, short description, responsibilities, requirements, “What we offer”, start date, publication date, “Valid until” and a Compensation field. Whatever is in the Compensation field appears on the page with the label “Compensation:” in the job card. The field is free text so that a range with a pay group, a note on the collective agreement or the pay for each year of training all fit equally well. For the page draft that XICflow generates from your description, the rule is not to invent responsibilities, pay or dates. You enter the pay yourself.
If you do not have a careers page yet, use “Insert templates” to add the “Careers” template from the page types. It comes with an introduction, cards on what makes the business a good employer, a section with open positions containing two sample jobs, a description of how the application works, and frequently asked questions. No pay is entered in the sample jobs; only your business knows the figure. How blocks and templates work in the editor is described in the documentation under Editor and pages.
- Create a careers page or insert the “Careers” template.
- In the “Job openings” block, enter the title, employment type and location for each position, with a gender-neutral title.
- Enter the range with its reference basis in the Compensation field: gross, per month or per year, full-time or number of hours, and the pay group if a collective agreement applies.
- Set the publication date and, if the vacancy is advertised for a limited period, “Valid until”.
- Choose how people apply, via the application form or by email, and publish the page.
For search engines, the page generates structured data of the JobPosting type for each position, provided a job title, publication date and description are present. It contains the title, description, date and employer, plus employment type and validity if they have been entered, and a work location if the business address is stored in full. It contains no salary field: because pay is free text, a figure derived from it would claim an amount that nobody entered in that form. What structured data can and cannot do is explained in the article on structured data in search results.
For apprenticeships, there is the Apprenticeship employment type. The pay is given there for each year of training, as in the template above. What else an apprenticeship needs on the website is covered in the article on apprenticeships on your website.
What XICflow does not do
What changes in the interview
With the range in the ad, one question drops out of the interview and another one comes in. What drops out is the question about previous pay, which Article 5(2) prohibits (EUR-Lex). That also applies to forms.
If your application form has a mandatory field for current pay, you should remove it; what else matters for mandatory fields in the application form is covered in the linked article.
What comes in is the question of where in the range someone starts. For each hire, briefly note which criteria were decisive. That takes a few minutes and helps if someone later asks why a colleague with similar experience was placed differently. In the interview, questions that target the criteria rather than the money help:
- Which of the tasks in the ad have you already carried out on your own?
- Which qualification or further training do you bring to the job?
- What responsibility for people, equipment or decisions have you had so far?
Common objections and what speaks against them
- “Then colleagues will know what new hires earn.” That is the heart of the matter. If a new colleague gets more than someone with longer service, the question is justified anyway, and the Directive gives workers their own rights to information. It is better if the difference can be explained by criteria.
- “Other employers will see our figures.” Once transposed, the obligation applies equally to all employers. The comparison already happens today, just in conversations with applicants who put several offers side by side.
- “We want to stay flexible.” A range is flexible. It sets the frame, not the amount, and the placement within the frame follows your criteria.
- “We pay according to the collective agreement anyway.” Then the range is quickly written: pay group, collective agreement and amount are fixed. The effort lies in writing it down, not in calculating.
- “The figures change every year.” Then updating the ad becomes part of the annual pay round. An outdated figure can do more harm than none; how to keep track of such statements is shown in the article on outdated statements in website copy.
The checklist for your next vacancy
- Criteria for placement set down in writing: requirements, experience, responsibility, working conditions.
- Lower and upper limit for entry determined, with pay group and collective agreement if one applies.
- Reference basis stated: gross, per month or per year, full-time or weekly hours.
- Job title worded in a gender-neutral way.
- Question about previous pay removed from the form and the interview guide.
- Publication date and, where applicable, “Valid until” set.
- Date for the next review of the amounts entered, for example after the next pay round.
The shortest route
You can see which blocks XICflow provides for careers pages and job openings on the features page. If you would like to know what your existing careers page would look like in XICflow, write to us via the contact form.
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