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A union analysis estimates employers withheld €64bn in wages, social contributions and tax since the minimum wage was introduced in 2015.

The German Trade Union Confederation (DGB) has calculated that minimum wage violations have cost employees, social security funds and the tax authorities up to €64bn since the wage floor was introduced in 2015. Based on an annual survey of 30,000 people across 20,000 households, the federation estimates that roughly two million workers each year take home less than the statutory €13.90 per hour.
The shortfall averages between €1.70 and €2.40 an hour per affected employee. Of the €64bn total, workers lost an estimated €35bn in net pay, while social security funds missed out on €22bn and the exchequer on €7bn in income tax. The DGB says the findings expose a enforcement gap that leaves legal protections far from universal.
Immigrants and recent arrivals are disproportionately affected, partly because they cluster in low-wage sectors such as hospitality, agriculture and logistics and are less familiar with German labour law. Research from the Friedrich-Alexander University in Erlangen-Nuremberg, published in Nature, found a 19.6% pay gap for first-generation immigrants, three-quarters of which stems from their concentration in lower-paid roles.
Gig-economy and subcontracted workers, including delivery drivers paid per drop rather than per hour, are especially vulnerable. Some firms avoid accountability by hiring through intermediary companies that can be dissolved when disputes arise, a practice the DGB says is illegal but difficult to police.
Responsibility for policing the Minimum Wage Act lies with the Financial Control of Undeclared Employment (FKS), a unit of the Federal Customs Administration. In 2024 it opened nearly 6,200 investigations, yet the DGB notes that 2,500 approved FKS positions remain unfilled. Statistically, a German company can expect an inspection once every 140 years.
Minimum wage violations are not a trivial offence, they must be rigorously prosecuted and severely punished.
DGB Vice President Stefan Körzell described part of the gap as "criminal actions by employers who do not comply with their legal obligations." The customs directorate in Bonn counters that the FKS pursues "quality over quantity," targeting fewer but more substantial cases.
Workers who suspect underpayment can call the minimum wage hotline on +49 30 60 28 00 28 or file a claim at a labour court without legal representation. Trade unions and works councils often provide support. Until staffing and inspection frequency rise significantly, however, the €64bn figure is likely to keep climbing.