Pay Transparency in Logistics: What's Coming for Fleet and Warehouse Operations

In a nutshell: In the logistics industry, we are used to thinking in clear metrics: delivery times, utilization rates, and fuel prices are transparent. But when it comes to pay, there has often been a "fog on the road". That is about to change. Germany must transpose the EU Pay Transparency Directive into national law by June 2026 at the latest. A comprehensive reform of the existing Pay Transparency Act is expected.

For logistics companies, this means: those who do not engage with the new requirements early on risk significant organizational overhead, rising compliance costs, and legal as well as employment law consequences. In particular, missing documentation and non-transparent compensation structures can quickly become a liability in the future.

This article does not constitute legal advice, but is intended to provide an initial impetus to address the topic in a structured manner together with the People and Legal teams and to prepare for implementation. The requirements are considerably more extensive than can be covered in this article; only selected key aspects are addressed here.

The Legal Framework: What Is Objectively Changing

The new Pay Transparency Act (EntgTranspG) significantly tightens the rules. Here are the key facts every logistics company must be prepared for:

• Right to Information & Comparability: Employees will receive significantly expanded rights to information about the company's compensation structures. This includes, in particular, information about their own pay compared to the average remuneration of employees performing the same or equivalent work. Comparison groups must be formed on the basis of objective, gender-neutral criteria, making it transparent how pay differences within comparable roles are composed.

   

• Reversal of the Burden of Proof: The directive significantly increases the requirements for demonstrating that pay decisions are based on objective criteria. Where pay differences are identified or apparent, the burden of proof lies with the employer, who must clearly demonstrate that these are based on objective, gender-neutral criteria. Transparent and consistent documentation of the underlying assessment standards is crucial. For companies with 100 or more employees, reporting obligations on the gender pay gap will be introduced gradually. This increases the pressure to systematically analyze and document compensation structures at an early stage.

   

• Pay Secrecy: Clauses in employment contracts that prohibit employees from discussing their salary are a thing of the past. Employers will no longer be permitted to prevent employees from talking about their pay.

Transparency in Recruiting

A critical aspect of the new directive concerns the application process. Here, transparency becomes both an obligation and an opportunity.

The salary range in the job posting: The directive requires that applicants be informed of the starting salary before the first interview. This means companies must communicate the salary range no later than before the initial meeting – for example, in advance by email or as part of the interview invitation. However, it is advisable to already disclose the average salary range directly in the job posting.

Why this makes sense:

1. Efficiency: It saves time in the recruiting process, as only candidates whose expectations align with the budget are approached.
2. Trust: 86% of candidates prefer job postings that include salary information*. It signals fairness before a single word has been exchanged.
3. Salary inquiries: Since employers will no longer be permitted to ask about a candidate's previous salary, proactively stating a range is the safest way to establish a fair basis for negotiation. 

*according to the Stepstone Salary Report (2025)

The Internal Challenge: Risks and Potential for Conflict

Every silver lining has a cloud. According to the Stepstone survey on the EU Pay Transparency Directive (2025), 36% of recruiters expect heated discussions within teams once pay structures suddenly become visible.

Particularly in logistics, where warehouse, fleet, and dispatch teams work in close coordination, unjustified pay differences can place a severe strain on the working environment. Historically grown compensation structures that cannot be objectively justified are especially problematic. Individual negotiation outcomes, varying starting salaries, or long-standing special arrangements can quickly become difficult to explain. 

The risk lies not only in legal claims, but in a loss of trust among the workforce.