Minimum Wage Act – Applying MiLoG in Compliance with the Law

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Since the initial introduction of the Minimum Wage Act (MiLoG) on August 11, 2014, the legal provisions have undergone several changes.

Ministerial decrees were intended to clarify specific individual matters.

However, in practice, there are still challenges in implementing § 17 MiLoG.

This section governs the creation and availability of documentation, outlines the employer’s recording obligations, and sets deadlines.

Exceptions to the minimum wage and income thresholds—some of which exempt employers from these recording requirements—are clearly defined, but have been nuanced or even overturned in favor of employers through individual court rulings.

After an initial "adjustment phase" in which authorities largely refrained from imposing penalties for violations, supervisory bodies are now consistently enforcing § 21 MiLoG.

The penalty provisions in § 21 MiLoG can result in significant fines of up to €500,000.

We would be happy to provide more information in a personal consultation.