Pay transparency obligations vary more sharply across jurisdictions than almost any other HR compliance requirement. Some countries require nothing; others require proactive salary disclosure before an interview, annual pay equity reporting, and joint remediation processes if a pay gap is found. The Pay Transparency Compliance Checker surfaces the current obligations for any country in its dataset. Below is a sample output for two common hiring destinations: Germany (mid-2026 transition) and the United Kingdom.
What Does This Tool Show?
For each country the tool returns: whether pay range disclosure is required in job advertisements or before interview; whether pay equity reporting is mandatory and at what employee threshold; the reporting cadence and deadline; and the penalty framework for non-compliance. It draws from verified government and legislative sources, updated when regulations change.
What Does the Sample Output Show for Germany?
Status as of June 2026: Germany is completing transposition of EU Pay Transparency Directive (2023/970/EU) into national law, with a statutory deadline of 7 June 2026.
| Requirement | Germany — post-June 2026 |
|---|---|
| Pay range disclosure in job ads | Not required in the ad itself, but must be provided proactively before the first interview |
| Proactive pay information to candidates | Yes — employer must disclose starting pay or range before interview stage |
| Pay equity reporting required | Yes |
| Reporting threshold | 150+ employees (down from 500+ under the old EntgTranspG) |
| Reporting cadence | Annual for 250+ employees; every 3 years for 150–249 employees |
| First report due | 7 June 2027 (covering calendar year 2026) |
| Gap trigger for remediation | Gender pay gap >5% that cannot be justified by objective factors triggers a mandatory joint pay assessment with employee representatives |
| Penalty framework | Effective, proportionate, and dissuasive fines — specific amounts to be set in German implementing legislation |
| Governing law | Pay Transparency Act (EntgTranspG) as amended; EU Directive 2023/970/EU |
Pre-June 2026 state for context: Before transposition, Germany’s old EntgTranspG required pay equity reporting only for employers with 500+ employees, with no proactive candidate disclosure requirement and weak enforcement. The 2026 changes materially increase the compliance burden for mid-sized employers.
What Does the Sample Output Show for the United Kingdom?
Status as of May 2026: The UK has not enacted EU-equivalent pay transparency legislation. Post-Brexit, the EU Directive does not apply. Current obligations are narrower.
| Requirement | United Kingdom |
|---|---|
| Pay range disclosure in job ads | No — no legal requirement. Recommended as good practice by ACAS |
| Proactive pay information to candidates | No — voluntary only |
| Pay equity reporting required | Yes — gender pay gap reporting only |
| Reporting threshold | 250+ employees (no change planned as of May 2026) |
| Reporting cadence | Annual |
| Reporting deadline | 4 April each year (private/voluntary sector); 30 March (public sector) |
| Gap trigger for remediation | No mandatory remediation — reporting only |
| Penalty framework | EHRC enforcement: investigation → unlawful act notice → court order. Non-compliance with court order is a criminal offence with unlimited fine |
| Governing law | Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 |
What Does the Gap Mean for Employers Hiring Across Both Markets?
A company with 150+ employees that hires in both Germany and the UK faces materially different obligations from June 2026. In Germany, every job offer requires a disclosed pay range or starting salary communicated before interview, and annual pay equity reporting begins for the 2026 reference year. In the UK, you report your gender pay gap once a year with no mandated remediation and no requirement to disclose salary to candidates at all.
If you use an EOR in Germany, the EOR is the legal employer — but the pay transparency obligations under the Directive apply to the “user undertaking” (the company directing the work), not just the legal employer. Your HR and talent acquisition processes need to adapt regardless of the employment structure.
Run the live checker against any country in the dataset to see current obligations. The tool flags when a jurisdiction is in transition — useful for compliance timelines when a new hire is being planned months in advance.
Sources: EU Pay Transparency Directive 2023/970/EU (effective June 2026); UK Equality Act 2010 (Gender Pay Gap Information) Regulations 2017; ACAS guidance on recruitment. Data verified April 2026.