Digital payslip portal: deliver payslips digitally to your employees
A digital payslip portal provides employees with their payslips, wage tax certificates and other HR documents in a personal, password-protected area where they can access, save and print every payslip online.
This is about the employer delivering payslips to employees, not about a salary comparison. The digital payslip portal from AWP Consult is AWP Consult's own product, works together with enaio and imports the payslips from your payroll software. AWP Consult has been a certified enaio partner since 2006. Printing, enveloping and posting are no longer needed.
- Payslip March 2026New
- Payslip February 2026
- Payslip January 2026
- Wage tax certificate 2025
Key facts at a glance
- A digital payslip portal is a password-protected online area in which the employer provides payslips and other HR documents for each employee instead of printing them and sending them by post.
- Following the ruling of the German Federal Labour Court (BAG) of 28 January 2025 (case no. 9 AZR 48/24), the employer generally fulfils its obligation under Section 108 of the German Trade Regulation Act (GewO) by placing the payslip in a password-protected digital employee mailbox.
- According to the BAG, individual employees do not need to consent to this, because the payslip is an obligation to be collected (Holschuld). Anyone without private access must be able to view and print the payslip on the company premises.
- If the portal is connected to the payroll system, its introduction is subject to co-determination by the works council (Betriebsrat) under Section 87(1) no. 6 of the German Works Constitution Act (BetrVG).
- The portal is a delivery channel, not an archive: under Section 41(1) of the German Income Tax Act (EStG), payroll accounts must be kept until the end of the sixth calendar year after the last entry, and under Section 147 of the German Fiscal Code (AO), accounting vouchers generally for eight years.
- The digital payslip portal from AWP Consult imports the payslips from the payroll software, sends notifications by email and can be connected to the digital personnel file in enaio.
Not sure where to start? We will assess your current situation.
Book an initial call +49 6104 94738-13What is a digital payslip portal and what does it not mean?
A digital payslip portal is a portal through which the employer issues payslips, wage tax certificates and other HR documents digitally to its own employees; it is not a salary comparison and not a salary database. Courts and specialist literature often refer to a digital employee mailbox. Anyone searching online for a salary portal, by contrast, mainly finds salary comparison sites.
For the HR department, the portal replaces monthly printing and posting. For employees, it is a place where all payslips are kept in order, including last year's, when a bank, landlord or authority asks for them.
The payslip is created in the payroll software as before and issued digitally instead of on paper.
The portal provides the payslip in the personal area and sends a notification by email.
Employees log in and see their current payslip and all previous ones.
In a demo, we show you how payslips from your payroll software arrive in your employees' personal area.
How does the payslip portal benefit HR and employees?
The payslip portal relieves the HR department of printing, enveloping, posting and many queries about old payslips, while employees can access their complete payslip history themselves at any time and their pay data no longer lies openly in the letterbox or on the desk. The switch to digital payslips therefore affects two sides, without anyone having to learn completely new processes.
Less routine work in HR
No printing, no enveloping, no returned post due to wrong addresses. Requests for old payslips decrease because employees find them themselves.
All payslips in one place
Employees access their payslip online whenever and wherever they want. The complete history remains available, even where the paper copy from three years ago would long since have been lost.
More protection for sensitive data
Payslips no longer lie openly in the mailbox, the locker or on the desk. Access is tied to login, and the data is stored encrypted.
Less paper
Every paper payslip means printing, an envelope and postage, month after month and for every employee. With the portal, this effort disappears once the switch is complete.
Paper, PDF by email or payslip portal: which is the most secure?
Of the three delivery channels, the payslip portal is generally the most secure, because the payslip remains encrypted with the employer and is only accessed after login, whereas paper can be misdelivered and a PDF sent by email remains permanently in private mailboxes over which the employer has no control. Nevertheless, many companies today send payslips as PDFs by email because it is quick.
| Criterion | Paper | PDF by email | Payslip portal |
|---|---|---|---|
| Effort for HR department | Print, envelope, distribute or post | Individual sending, maintaining email addresses | Import, automatic provision |
| Data protection | Risk of misdelivery and open storage | Payslip sits in third-party mailboxes, misdirection to wrong address possible | Stored encrypted, access only after login |
| Availability | Only as long as the paper is kept | Depends on the personal mailbox | Entire history available at any time |
| Employees without internet | No problem | Not possible | Enable viewing and printing on site |
Would you like to see this with your own documents?
How does the payslip reach employees digitally?
The payslip reaches employees digitally when the HR department imports the finished payslips from the payroll software into the portal, the portal files each payslip in the personal area and triggers an email notification, and employees access the document in the browser after logging in. Little changes for the HR department: instead of printing and enveloping, it hands the payslips over to the portal.
01
Payslip in the payroll software
The payslip is created as usual in your payroll software. Nothing changes in your payroll process.
02
Import via the interface
The payslips are imported into the portal via an interface. There is no need to upload individual files manually.
03
Provision in the personal area
Each employee has their own area in the portal. The new payslip is stored there alongside all previous payslips.
04
Email notification
As soon as a new payslip is available, employees receive an email. It points to the new document, which is accessed in the portal.
05
Access in the browser
After logging in, employees access their payslips in the browser. The portal is platform-independent and runs on common devices.
How many employees, which payroll software, which documents? In a demo, we show you the payslip portal with your scenario.
Book a demoIs a digital payslip portal legally permitted?
Yes. In its judgment of 28 January 2025 (case no. 9 AZR 48/24), the German Federal Labour Court (BAG) ruled that an employer generally fulfils its obligation under Section 108 of the German Trade Regulation Act (GewO) to issue a payslip in text form by placing it in a password-protected digital employee mailbox, provided that employees without their own access can retrieve the payslip on the company premises.
According to the judgment, the entitlement to the payslip is an obligation to be collected (Holschuld). The employer must make the payslip available; it does not have to ensure that the payslip reaches the employees. Whether employees have consented to digital transmission is therefore irrelevant under the judgment.
The condition for employees without their own access is important: anyone who has no private access to digital media must be able to view and print the payslips on the company premises. Nobody has to buy their own equipment to obtain their payslip.
What else the judgment shows
The mailbox needs a secure, individual storage area that the employer cannot subsequently alter.
If the mailbox is connected to the payroll system, its introduction is subject to co-determination under Section 87(1) no. 6 of the German Works Constitution Act (BetrVG).
The BAG referred the case back to the Regional Labour Court to clarify whether the group works council was responsible.
This summary does not replace legal advice. Coordinate the introduction with your legal advisers and, if there is one, the works council (Betriebsrat).
We discuss co-determination with you, access for employees without their own devices and the import route from your payroll software.
- Solution for employees without devices
- Import from payroll software
- Transition phase with paper
What legal and technical points apply to digital payslips?
With digital payslips, five points matter above all: text form under Section 126b of the German Civil Code (BGB), access for employees without their own devices, co-determination by the works council (Betriebsrat), data protection appropriate to the risk under the GDPR, and retention outside the portal. Technology is the smaller part. The following sections summarise the rules for HR, IT and data protection.
We clarify with you which technical and organisational points are still open before the launch, from the login procedure to the run-off period for leavers.
Discuss the introduction +49 6104 94738-1301
What the BAG ruling specifically requires
Section 108(1) of the German Trade Regulation Act (GewO) requires a payslip in text form when wages are paid, showing at least the pay period and the composition of the pay. If the details have not changed since the last proper payslip, the obligation lapses under Section 108(2) GewO.
Text form under Section 126b of the German Civil Code (BGB) means: a legible declaration, naming of the person making it, and a durable medium. The BAG recognised the employee mailbox as a durable medium because only the employee has access with a username and password and the employer can no longer alter documents once placed there. Employees must be able to save and print the payslips.
Fulfilment does not require receipt under Section 130 of the German Civil Code (BGB), because the payslip is a declaration of knowledge. In the case decided, the documents were available for twelve months, which the court regarded as an appropriate period.
Keep payslips in the portal for well over twelve months. Employees need older payslips for loan or rental applications, for example, and HR saves itself queries.
02
Employees without their own devices
The judgment's condition is clear: anyone without private access must be able to view and print the payslip on the company premises, and during working hours. In production, logistics, care or cleaning, this often affects a significant part of the workforce. Proven approaches:
- Shared terminal a fixed PC or kiosk computer with automatic logout after a short period of inactivity and no local caching.
- Protected printingPrinting only after release at the printer, so that no payslip lies openly in the output tray.
- Dedicated contact personSupport with first login and lost passwords in the HR department, with identity verification.
- Provision in the works agreementLocation, times and procedure are set out in writing and communicated to employees.
Before the switch, ask who has no private access or needs support. Then you can plan terminals and help desk hours according to real demand.
03
Co-determination and rollout path
A portal connected to the payroll system is a technical device within the meaning of Section 87(1) no. 6 of the German Works Constitution Act (BetrVG). Its introduction and use therefore require the approval of the responsible works council body. In the BAG case, it was unclear whether the group works council or the local works council was responsible. Clarify this question first.
The works agreement typically governs purpose, document types, availability period, access without own devices, logging, handling of leavers and data processing on behalf. This is followed by the rollout path in three steps:
- InformationLetter with cut-off date, instructions and contact person, ideally with the last paper payslip.
- RegistrationFirst access via a personal activation code sent through a separate channel, for example by post to the home address or handed over in person.
- Transition phasePaper and portal in parallel for a few payroll months, with an evaluation of who has not yet registered.
Start with a payroll run without special payments. Questions about logging in and questions about the payslip itself should not arise in the same month.
04
Data protection under Art. 5, 25 and 32 GDPR
According to the BAG, the legal basis for providing payslips is the statutory obligation to issue them (Art. 6(1)(c) GDPR in conjunction with Section 26(1) of the German Federal Data Protection Act (BDSG)). An external operator is involved as a processor under Art. 28 GDPR. This results in three checkpoints.
- Art. 5 GDPRData minimisation and purpose limitation: the portal only holds data that also appears on the paper payslip. Storage limitation: there is a defined availability period and a deletion rule.
- Art. 25 GDPR data protection by default: the notification email contains no payslip as an attachment and no amounts, only a notice of a new document.
- Art. 32 GDPRSecurity of processing: encryption in transit and at rest, role-based administration, logging, data backup and regular review of the measures.
Payslips often contain the church tax indicator and wage garnishments. Religious affiliation is one of the special categories of personal data under Art. 9 GDPR. Do not therefore rate the level of protection lower than for the personnel file.
05
Access security and two-factor login
A username and password are the minimum requirement from the judgment. For pay data, that is not much. The German Federal Office for Information Security (BSI) recommends using two-factor authentication wherever it is offered: in addition to the password, a second factor is checked, such as a one-time code from an app.
The process around the login is just as important as the login itself. A password reset must not run through a weaker channel than the login itself. Failed attempts lead to a temporary lock, and inactive sessions are terminated. Notifications should never ask users to enter login details via a link, so that employees can recognise phishing emails more easily.
In the project, clarify which login procedures are practical for your workforce. A second factor via an app requires a smartphone and needs an alternative for employees without their own device.
06
Retention by the employer and leaving the company
The portal is a delivery channel, not the employer's archive. The retention obligations are met by the payroll system and the personnel file: under Section 41(1) of the German Income Tax Act (EStG), the payroll account must be kept until the end of the sixth calendar year after the last entry, and payslips as accounting vouchers generally for eight years under Section 147 of the German Fiscal Code (AO).
When an employee leaves, the employer closes the payroll account and issues the wage tax certificate (Section 41b(1) of the German Income Tax Act, EStG). Documents often still follow: the final payslip, corrected payslips, the social security notification certificate. You should therefore set a run-off period during which access remains active.
For audit-proof retention by the employer, the digital personnel file or archiving software that supports immutability and deletion periods is suitable. The linked page describes how a GoBD-compliant DMS retains payslips as accounting vouchers.
- Notify leavers to save documents by a cut-off date
- Access remains active for the agreed run-off period
- Then deactivation, later deletion according to the defined rule
- Deliver documents created later through another channel
Write the run-off period into the works agreement and the leaving letter. Then there is no discussion about whether access was blocked too early or too late.
Which documents can a digital payslip portal provide besides the payslip?
In addition to the monthly payslip, a digital payslip portal can provide the wage tax certificate, the social security notification certificate, earnings certificates for social benefits and other HR documents that are currently sent by post, provided the required form of each document allows electronic provision. Before the launch, we check which documents your payroll software supplies for import.
| Document | Legal basis | Notice |
|---|---|---|
| Payslip | § 108 GewO | In text form with every payment, not required if details are unchanged |
| Wage tax certificate | § 41b(1) EStG | To be handed over as a printout or provided electronically, at year end or on leaving |
| Social security notification certificate | § 25 DEÜV | Certificate of the reported data, at least once a year by 30 April for the previous year |
| Earnings certificate for social benefits | § 108(3) GewO | For purposes under the German Social Code, for example towards authorities |
| Other HR documents | depending on the document | HR-relevant documents that you define, in the same personal area |
Not legal advice. Check the required form for each document type with your payroll provider or tax adviser.
How secure is a digital payslip portal under the GDPR?
Under the General Data Protection Regulation (GDPR), a digital payslip portal is secure enough if each employee sees only their own area, access is tied to a login, the data is stored encrypted and only details that also appear on the paper payslip are processed. This matters because payslips contain tax and social security data, bank details, church tax information and sometimes details of wage garnishments. They therefore require an appropriate level of protection under Art. 32 GDPR.
In the case decided, the BAG considered processing in the digital mailbox to be justified under data protection law, partly because only the data shown on the paper payslip was processed. Our page on GDPR-compliant document management describes the overarching rules for roles, deletion periods and data processing on behalf.
Each employee sees only their own documents.
Access is only granted after authentication in the portal.
Sensitive data is encrypted and stored securely.
The portal is designed for the GDPR-compliant provision of HR documents.
With the digital personnel file in enaio, payslips are also stored in an audit-proof manner in the HR department.
Connection to payroll software, personnel file and other portals
The payslip portal does not stand alone. It takes over data from your payroll software and can be connected to other AWP Consult solutions for HR and documents.
Payroll software
The payslips are imported via interfaces from your payroll software. Before the launch, we check which export formats your system supplies.
Digital personnel file
In the enaio personnel file, payslips automatically end up in the right file, with retention and deletion periods.
Digital personnel fileDigital learning portal
Delivers training and safety briefings to employees in the browser in the same way, with progress tracking.
Digital learning portalLink and upload portal
For exchanging documents with external parties, with access via link and password and limited validity.
Link and upload portalIf you use enaio for HR documents, you can also run contract management with deadline monitoring and the digital project file on the same platform. How such projects fit into an overall architecture is clarified by enterprise content management consulting.
Prefer to talk it through rather than read on?
Common mistakes when switching to digital payslips
In practice, these mistakes lead to complaints, queries or legal risks. All of them can be avoided before the cut-off date.
Works council involved only after launch
- Consequence
- The introduction is open to challenge; if in doubt, you have to switch back to paper.
- Better
- Clarify the responsible body and conclude the works agreement before the cut-off date.
No solution for employees without a device
- Consequence
- The condition from the BAG ruling is not met; the obligation to provide payslips may not have been effectively fulfilled.
- Better
- Terminal or PC with printing option on site, with times and procedure defined.
Payslip attached to the notification
- Consequence
- Pay data ends up in private mailboxes after all.
- Better
- Email only as a notice, access exclusively in the portal.
Activation code sent the same way as the access address
- Consequence
- Anyone who intercepts one message can log in.
- Better
- Send the code and the access details through separate channels.
Access blocked on the leaving date
- Consequence
- The final payslip and wage tax certificate do not reach leavers.
- Better
- Set a run-off period and inform leavers in advance.
Portal treated as the only archive
- Consequence
- Retention obligations under § 41 EStG and § 147 AO are not covered.
- Better
- Also store payslips in an audit-proof manner in the payroll system or personnel file.
Not sure where to start? We will assess your current situation.
Book an initial call +49 6104 94738-13Checklist for introducing the payslip portal
With these points, the switch is prepared legally, technically and organisationally.
01
Law and co-determination
- Responsible body clarified: works council, central or group works council
- Works agreement with document types, availability period and run-off period
- Arrangement for employees without their own access
- Data processing agreement, if a service provider is involved
- Entry in the record of processing activities
02
Technology and security
- Import route from the payroll software tested with test payslips
- Login procedure and password reset defined
- Notification without attachment and without amounts
- Terminal and protected printing set up on site
- Retention in payroll system or personnel file arranged
03
Communication and launch
- Letter with cut-off date and instructions
- Activation codes distributed through a separate channel
- Contact person and help desk hours named
- Transition phase with paper and portal in parallel
- Registration status checked before paper delivery ends
How do you introduce a payslip portal so that employees accept it?
A payslip portal is introduced in five steps: clarify co-determination, test the interface to the payroll software, inform employees, run paper and portal in parallel for a few months and only then stop paper delivery, while viewing and printing on site remain permanently available for employees without their own access. Technically, the payslip portal is set up quickly. Whether it works in everyday use depends on acceptance. Most questions arise in the first payroll months: how do I log in, what do I do if I forget my password, where do I find an old payslip? A short guide and a dedicated contact person solve most of them.
01
Agreement with the works council
Clarify co-determination and define the arrangement for employees without their own access.
02
Interface
Set up the import route from your payroll software and check it with test payslips.
03
Information
Inform employees in good time: what is changing, how login works, where to get help.
04
Transition period
Paper and portal in parallel for a few payroll months, until logins are running smoothly.
05
Switchover
Paper delivery ends. Viewing and printing on site remain possible for everyone without their own access.
Would you like to deliver payslips and at the same time store them audit-proof in the personnel file? We show how both work together with enaio.
Frequently asked questions about the digital payslip portal
What is a digital payslip portal?
A digital payslip portal is a protected online area in which the employer provides its employees with payslips, wage tax certificates and other HR documents. Employees are notified by email and access the documents in the browser after logging in. The payslips are imported from the payroll software. HR no longer has to print and post them.
Is a digital payslip portal a salary comparison?
No. The digital payslip portal from AWP Consult is used to deliver payslips to your own employees. It has nothing to do with salary comparisons or salary databases. Each employee sees only their own documents.
May I provide payslips only digitally?
In principle, yes. Following the ruling of the German Federal Labour Court (BAG) of 28 January 2025 (case no. 9 AZR 48/24), the employer generally fulfils its obligation under Section 108 of the German Trade Regulation Act (GewO) by placing the payslip in a password-protected digital employee mailbox. The prerequisite is that employees without private access can view and print the payslip on the company premises. Where there is a works council (Betriebsrat), it must be involved.
What applies to employees without a computer or smartphone?
Anyone without private access to digital media must be able to view and print the payslips on the company premises. Nobody has to buy their own devices to receive their payslip. In practice, a terminal with automatic logout and protected printing has proven effective. The location and procedure should be set out in the works agreement.
Do I need the consent of every employee?
According to the BAG ruling, it does not matter whether employees have consented to digital transmission. The reason is that the entitlement to the payslip is an obligation to be collected (Holschuld) and receipt is not required. Irrespective of this, a works council (Betriebsrat), if there is one, must be involved. Under data protection law, provision is based on the statutory obligation to issue payslips, not on consent.
Does the works council have to approve?
If the portal is connected to the payroll system, its introduction is, in the BAG's view, subject to co-determination under Section 87(1) no. 6 of the German Works Constitution Act (BetrVG). Where there is a works council, the introduction should therefore be governed by a works agreement. Clarify in advance whether the local, central or group works council is responsible. This is exactly the question the BAG referred back to the Regional Labour Court in the case decided.
How long must payslips be available in the portal?
There is no statutory minimum period. In the BAG case, the documents were available for twelve months, which the court considered appropriate because employees can save and print them. Many companies keep payslips in the portal for longer to avoid queries. The employer's retention obligations are met separately in the payroll system or personnel file.
Is two-factor login mandatory?
The GDPR does not prescribe a specific procedure, but Art. 32 requires a level of protection appropriate to the risk. Pay data is sensitive, and the German Federal Office for Information Security (BSI) recommends two-factor authentication wherever it is offered. An alternative for employees without a smartphone is important. We clarify in the demo which procedures suit your environment.
Can I provide the wage tax certificate via the portal?
Yes. Under Section 41b(1) of the German Income Tax Act (EStG), the wage tax certificate must be handed to employees as a printout or provided electronically. In the payslip portal, it sits alongside the monthly payslips. This applies at year end and when an employee leaves and the payroll account is closed.
What happens to access when someone leaves the company?
You decide, ideally in the works agreement. After leaving, the final payslip, the wage tax certificate and the social security notification certificate often still follow. A run-off period with active access and a notice to save documents by a cut-off date have proven effective. Access is then deactivated.
Which payroll software can be connected?
The payslips are imported via interfaces from your payroll software. Before the launch, we check together with you which export formats your system supplies. Test payslips are used to check that each payslip lands in the correct personal area. Only then does the portal go live.
On which devices does the digital payslip portal work?
The portal is browser-based and platform-independent. Employees use it on a PC, tablet or smartphone without having to install a separate app. For employees without their own device, access on the company premises is available.
Would you like to see this with your own documents?
Glossary: terms relating to digital payslips
The key terms from employment law, tax law and IT security, briefly explained.
01
Digital employee mailbox
Password-protected personal area in which the employer provides documents for an employee.
02
Obligation to collect
Performance that the creditor collects from the debtor. For the payslip, it is therefore sufficient to make it available.
03
Text form
Form under Section 126b of the German Civil Code (BGB): legible declaration, naming of the person making it, durable medium, without signature.
04
Durable medium
Medium on which a personally addressed declaration can be stored and reproduced unchanged.
05
Payslip
Statement under Section 108 GewO showing the pay period and the composition of the pay, including supplements and deductions.
06
Wage tax certificate
Certificate under Section 41b EStG of wages and taxes withheld for a year or up to the date of leaving.
07
Notification certificate
Certificate of data reported to social security under Section 25 of the German reporting ordinance (DEÜV).
08
Payroll account
Record of wage payments and deductions under Section 41 EStG, kept and retained by the employer.
09
Two-factor authentication
Login with two independent proofs, such as a password and a one-time code from an app.
10
Data processing on behalf
Processing of personal data by a service provider on behalf of and on the instructions of the employer, governed by Art. 28 GDPR.
Sources and legal basis
The legal statements on this page are based on the following official sources. Review status: October 2026.
- BAG, judgment of 28 January 2025, 9 AZR 48/24 Payslip in the digital employee mailbox
- § 108 GewO Payslip for wages in text form
- § 126b BGB Text form and durable medium
- § 87 BetrVG Co-determination on technical devices, para. 1 no. 6
- § 41 EStG Payroll account and retention period
- § 41b EStG Wage tax certificate as printout or electronically
- General Data Protection Regulation (EU) 2016/679 Official full text of the regulation
- BSI: two-factor authentication Recommendation of the German Federal Office for Information Security
Digital payslips, starting next month
In a demo, we show you the digital payslip portal and discuss payroll software, document types, rollout and the arrangement for employees without their own access.
- In person in Dietzenbach or online
- With HR and payroll
- Result: a clear roadmap for the switch