EU Pay Transparency: Unprepared pays the price

The EU Pay Transparency Directive brings major changes for all employers by mid-2026 at the latest.

Extended disclosure rights, transparency requirements, and reporting obligations will soon apply not just to companies with 200+ employees—but to everyone. The risks? Back pay, compensation claims, fines, and more.

Step by step to pay compliance

Our Pay Transparency Masterplan combines structured live training with our digital modules into one complete package for seamless implementation.

Live Training on Pay Transparency: Nine sessions with practical implementation steps, templates, and sample documents aligned with EU requirements
Q&A Module: Reliable support on all labor law questions, whenever you need it
Template Pool: Legally sound documents and templates for pay transparency and beyond
Additional Modules: Separation Manager, Freelancer Check, and Employment Reference Generator for your day-to-day HR work

"We already pay fairly and neutrally, so we're surely well prepared"

Not quite. The shift in burden of proof makes it essential to adapt your processes, job descriptions, and salary evaluations to align with EU requirements. Sitting this one out means losing your head start and risking fines and back payments..

"Let's wait and see how the final, national implementation will look..."

Bad move. The core requirements are set in stone—the legislator has no wiggle room. Plus, implementation is extensive. Wait until the last minute and you'll be racing the clock with zero room to maneuver.

(More on such pitfalls in our HR & Legal Blog.)

The Pay Trans­parency Master­plan

Live sessions, ready-to-use templates, and digital access to labor law expertise

#1 – Designing Pay Structures with Legal Certainty

with RAin Christiane Milbradt, LL.M. (Münster Legal Experts))

  • Define equivalence criteria objectively and neutrally
  • Design job evaluation systems and pay bands with legal certainty
  • Identify comparison groups for equal and equivalent work

Outcome: Development of your own criteria based on a comprehensively annotated template

#2 – Analyzing Salaries and Resolving Inequalities

including ready-to-use calculation tool for comparison group analysis

  • Systematically calculate pay gaps and apply the 5% rule
  • Identify gender pay gaps and intersectional discrimination
  • Justify salary differences within comparison groups
  • Handle outliers that disproportionately distort comparison groups

Outcome: Understanding concrete back-payment risks, early correction of outliers

#3 – Q&A Session: Pay Structure Design
  • Experience sharing on analysis results and initial challenges
  • Discussion of legal gray areas
  • Preparation for the correction and implementation phase

Outcome: Deriving the right implementation steps from analyses, completing the exploration phase

#4 – Mastering Burden of Proof Reversal – Documentation and Legal Safety
  • Checklists for legally sound justifications of pay decisions
  • Handling critical employee inquiries and discrimination allegations
  • Template language and documentation templates for practical use

Outcome: Uniform documentation standards for legal certainty in disputes

#5 – New Leadership: Rules for Salary Negotiations & More
  • Align managers with objective pay criteria and procedures, ensure thorough documentation
  • Establish structured salary determination and replace discretionary practices
  • Professionally manage employee reactions to new transparency

Outcome: Concrete content that can be shared with leadership teams

#6 – Information and Disclosure Processes, Recruiting Compliance
  • Efficiently establish disclosure procedures and ensure 2-month deadlines
  • Systematically implement annual information obligations to employees
  • Design recruiting processes according to directive requirements

Outcome: Building operational processes with our templates, adapting workflows

#7 – Closing the Remaining Gaps: Legislative Updates
  • Besprechung der im Referentenentwurf getroffenen Gestaltungsentscheidungen
  • Strukturierte Gehaltsfindung etablieren und diskretionäre Praktiken ablösen
  • Mitarbeiterreaktionen auf neue Transparenz professionell managen

Ergebnis: Action Items zur Umsetzung der im Gesetz­gebungsverfahrens konkretisierten Regelungen

# 8 – Q&A Session: Last Questions Before Go-Live
  • Offene Runde für alle ungeklärten Fragen zur EU-Entgelttransparenz
  • Erfahrungsaustausch bzgl. des ersten Mitarbeiter-Feedbacks
  • Abschließende Tipps und Hinweise vor dem Stichtag

Outcome: Timely solutions to remaining questions, full compliance by June 7, 2026

#9 – Establishing Efficient Reporting Processes
  • Transform existing pay evaluations into reports
  • Examples and templates for quick implementation in your context

Outcome: Template reports and methods for report creation and submission

HR departments already trusting twinwin

Get in touch

Prefer email or a call over booking a calendar slot? Nothing easier than that:

Dipl.-Jur. Karol M. Czuba
Phone: +49 1522 9481769
Email: karol@twin.win

Karol is Co-Founder of twinwin and happy to answer any questions about the Masterplan – from fit and suitability to all the nitty-gritty details.

Ready to get started?

Our Masterplan brings you full compliance by mid-2026 – without €50k law firm projects, without tedious legal research. In a free strategy call, we'll walk through how this works for your company and what implementation looks like.

Next start: 30. October 2025

Book your free Strategy Call

Common Questions

Who's the Masterplan for?

Companies of any size operating in Germany that want to implement EU pay transparency properly and timely. Whether you have 10 or 1,000 employees—the Masterplan scales to fit.

How much time should I plan for?

Nine live sessions at 90 minutes each, spread across six to nine months depending on your start date. The digital modules are yours to use flexibly. Imple­men­tation can be estimated in your Strategy Call.

Pay Transparency – and after that?

The twinwin platform with Question & Answer, all other modules, and templates stays with you for ongoing compliance and all German employ­ment law matters. We're happy to adjust the initial term until mid-2026, if you wish.

What are the costs?

Our standard pricing applies, which is based on company size. We usually cover that in the strategy call, but feel free to check out our pricing calculator if you are curious. (Spoiler: It's far from a €50k project.)