The Federal Civil Service Association (DBB) has issued a statement criticizing several components of the proposed pay reform bill, calling parts of the legislation potentially unconstitutional, even as the association welcomes the reform in principle.
Under the reform, Federal Interior Minister Alexander Dobrindt (CSU) announced mid-April plans to increase the starting salaries for federal civil servants. The major change involves the structure of salary progression; civil servants would no longer receive pay based on the first level of experience, but would instead enter service directly at the second level.
Furthermore, the bill intends to shift away from the “sole earner principle” when calculating compensation. Currently, civil service salaries are assumed to be sufficient to support a household of four. Moving forward, the pay calculation will assume a partner income of roughly €20,000 annually. The DBB objected strongly to this calculation method, arguing that the level of the partner’s income cannot be mandated by the civil servant and is based on the actions of third parties. They characterized the proposal as an “unacceptable fiscal downward adjustment of the provision claim”.
A second area of concern regards the B-scale compensation. Dobrindt plans to raise salaries in the B-scale less steeply than in the A-scale, primarily transferring pay results from public service employees to top-tier civil servants. The DBB therefore advocated for a critical review of the existing gaps between income groups in the B-scale. Specifically, the planned 1.6% distance between pay groups B 3 and B 4 is deemed incompatible with both the performance principle and mandatory separation standards.
These objections highlight two key requirements drawn from the Basic Law: the performance principle, which mandates that salary should reflect the civil servant’s professional aptitude, and the gap rule, which requires minimum spacing between pay groups. According to the DBB’s figures, the reform fails to maintain the mandated distances within the B-scale. The Federal Interior Ministry declined to comment on the gap requirements concerning the B-scale when approached by the newspaper.



