Updated on August 21, 2026: This post was written as a preview of the year 2026. It now provides the actual status for each item, including the expired implementation deadline for pay transparency and the expired NIS 2 registration deadline.
Numerous legal changes took effect at the turn of the year 2025/2026, with more to follow throughout the year. They range from labor law to competition law and IT law, and even extend to civil procedure law. The following overview provides the status of each item as of August 21, 2026.
Labor law: Higher wages, new transparency obligations
Higher Minimum Wage: As of January 1, 2026, the statutory minimum wage is 13.90 euros gross per hour. This is based on the Fifth Minimum Wage Adjustment Ordinance, which the Federal Cabinet adopted on October 29, 2025. As of January 1, 2027, the minimum wage will rise to 14.60 euros.
Minijob earnings limit: Because the limit is tied to the minimum wage, it has been 603 euros per month since January 1, 2026. Minijobs remain exempt from social security contributions but allow for a higher income.
Easier Continued Employment After Retirement: As of January 1, 2026, employers may continue to employ retirees on a fixed-term basis without cause after they have reached the standard retirement age, even if an employment relationship previously existed. The prohibition on prior employment under Section 14(2), second sentence, of the TzBfG does not apply in these cases. The law sets limits on the total duration of eight years and the number of contracts.
Pay Transparency: The current situation differs from what was expected at the time this article was published. The deadline for implementing the EU Pay Transparency Directive expired on June 7, 2026, yet there is still no German implementing law; the Cabinet is scheduled to address the matter in August 2026. This is not without legal consequences: As of June 8, 2026, the directive takes direct effect for public employers, and for private employers, it applies through Article 157 of the TFEU and its interpretation in accordance with the directive. Employers should therefore prepare for:
- State salary details or salary ranges in job advertisements,
- provide employees with information on comparative salaries,
- prepare regular remuneration reports (from 100 employees),
- bear the burden of proof for fair payment in the event of a dispute.
Competition law & advertising law: Greenwashing becomes risky
Stricter Rules for Environmental Claims: The German law implementing the EmpCo Directive (EU) 2024/825 was promulgated on February 19, 2026. The new provisions in the UWG will take effect on September 27, 2026. Among other things, the following will then be prohibited:
- blanket environmental promises without independent proof,
- Sustainability seal without certification,
- Statements such as “climate-neutral” or “CO₂-positive” on a mere offsetting basis,
- misleading information on the shelf life or reparability of products.
Anyone who uses environmental claims in their advertising should review their advertising materials before September 27, 2026.
IT, data protection & digital law: new obligations for companies
AI Regulation: Labeling requirement effective as of August 2026: AI-generated content must be clearly labeled as such. For operators, the requirement under Art. 50(4) of the AI Regulation has been in effect since August 2, 2026, with no transition period. This applies in particular to:
- Chatbots,
- Deepfakes,
- Content on topics of public interest.
Article 50(2) of the AI Regulation applies to providers, with a transitional provision for systems that were on the market before the effective date. What this means for advertising, social media, and law firm communications is explained in detail in our article on AI labeling. High-risk AI systems are subject to additional requirements.
NIS-2: Requirements Are Already in Effect: The NIS-2 Implementation Act entered into force on December 6, 2025. The following companies are affected:
- at least 50 employees or
- more than € 10 million in annual sales.
The registration deadline with the BSI expired on March 6, 2026. The BSI accepted late registrations until July 31, 2026, but this grace period has also expired. Anyone who has not registered by today risks a fine, even without a security incident having occurred. In addition, there are obligations regarding security measures and incident reporting.
Sales, consumer & e-commerce law
Right to Repair: The law implementing Directive (EU) 2024/1799 has been promulgated and is effective as of July 31, 2026. Consumers can have certain products, such as household appliances, smartphones, and tablets, repaired at a reasonable price even after the warranty has expired. For sales contracts concluded before July 31, 2026, the previous law remains in effect.
Cancellation Button in Online Retail: As of June 19, 2026, online stores must provide an easily locatable cancellation button (Section 356a of the German Civil Code (BGB)). The cancellation process must be as simple as entering into the contract. Stores without this button are subject to cease-and-desist letters as of that date. This is distinct from the termination button under Section 312k of the German Civil Code (BGB), which has been in effect since July 1, 2022.
New Disclosure Requirements Regarding Warranties and Guarantees: Starting September 27, 2026, manufacturers and retailers must clearly disclose information about warranty and guarantee claims, including through standardized EU labels. This requirement is part of the same implementing law as the new rules for environmental claims.
Civil procedural law: Procedures are being restructured
Local courts have jurisdiction over cases up to 10,000 euros: As of January 1, 2026, local courts have jurisdiction over civil cases up to 10,000 euros (Section 23 GVG); previously, the limit was 5,000 euros. The decisive factor is that the proceedings become pending on or after that date (Section 44 EGGVG); in ongoing proceedings initiated before that date, the old jurisdiction rules remain in effect. Another new development is that disputes regarding publication—regardless of the amount in dispute—must be brought before the regional court (§ 71(2)(7) GVG). This applies to the press, broadcasting, and the Internet.
Higher thresholds for appeals: Since January 1, 2026, the threshold for appeals and complaints has been set at over 1,000 euros (Section 511(2)(1) of the Code of Civil Procedure (ZPO)); previously, it was over 600 euros. An appeal against denial of leave to appeal to the Federal Court of Justice requires a dispute amount exceeding 25,000 euros (Section 544 of the Code of Civil Procedure). For amounts below 1,000 euros, an appeal is only possible with express leave; thus, the first instance is often the final decision in such cases.
Frequently asked questions
What major legislative changes will take effect in 2026?
At the turn of the year 2025/2026, numerous changes will take effect—in labor law (higher wages, transparency requirements), in competition law (stricter rules for green claims), in IT and data protection law, and in civil procedure law.
What changes are coming to labor law?
Among other things, minimum wages and collectively bargained wages are increasing, and new transparency requirements are in effect, such as those related to equal pay.
What should companies do now?
Review and update contracts, advertising claims, and internal processes early on to ensure they comply with the new requirements.
Changes in the law bring new obligations every year—including in labor law. We’re here to advise you so that you can ensure your business is in full compliance with the law. Learn more on our labor law page.
