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Employment law update: Proposed legislation 2024

Revision of the Working Hours Act

As a result of the rulings of the European Court of Justice and the Federal Labor Court, which have established an obligation to record working hours, there is a need to revise the Working Hours Act. A draft bill has been available since spring last year, meaning that the law could theoretically be passed in spring or summer 2024. However, this is not yet foreseeable.

Employee Data Protection Act

After the European Court of Justice deemed the wording of Section 26 (1) sentence 1 BDSG to be non-compliant with European law in its ruling of March 30, 2023, there is an urgent need to revise key provisions of the BDSG by means of an Employee Data Protection Act. Although there have been initial drafts of this in the past, no real consensus has yet emerged. However, new regulations could be introduced in the course of 2024.

European Pay Transparency Directive

Employers must then expect significantly more extensive obligations with regard to establishing pay transparency and equal pay. However, the transposition deadline is not until June 7, 2026, so German legislators still have sufficient time to react. It is therefore highly questionable whether a new regulation will be introduced in 2024.


Michael Wahl

Michael Wahl


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