A quiet revolution is brewing in German factories and workshops. Disabled workers, long relegated to segregated workplaces and paid a fraction of minimum wage, are now demanding equal pay. Their lawyers are holding up the United Kingdom as the benchmark. Documents uncovered by this newsroom show that the UK’s Equality Act 2010, with its robust provisions for reasonable adjustments and pay parity, is being cited in German court filings as a template for reform.
Sources close to the German disability rights movement confirm that five major lawsuits are pending before labour courts in Berlin, Hamburg and Munich. The plaintiffs argue that the current system, which pays disabled employees in sheltered workshops as little as 1.50 euros per hour, violates the UN Convention on the Rights of Persons with Disabilities. Germany ratified the convention in 2009, but implementation has been patchy at best.
“The British model is not perfect, but it is light years ahead of where we are,” said a senior lawyer involved in the cases, speaking on condition of anonymity. “In the UK, a disabled worker in a supported environment can earn the national minimum wage. Here, they are treated as second-class citizens.”
Germany’s so-called Werkstätten, or sheltered workshops, employ around 300,000 disabled people. These facilities are often run by charities or local authorities and operate outside mainstream labour law. Workers are classified as “employees in a special status,” exempting employers from paying minimum wage, holiday pay, or sick leave. The average wage is under 200 euros per month.
The UK’s approach, by contrast, integrates disabled workers into the open labour market wherever possible, with state subsidies for employers who make reasonable adjustments. The Equality Act also prohibits pay discrimination on grounds of disability. In 2023, the UK Supreme Court ruled that paying disabled workers less than non-disabled colleagues for equivalent work could constitute direct discrimination.
Documents obtained by this newsroom reveal that German disability advocacy groups have been quietly studying the UK’s legal frameworks for years. A confidential memorandum from the German Institute for Human Rights, dated March 2024, explicitly recommends adopting key elements of the UK’s equality legislation. The memo warns that continued non-compliance with the UN Convention could lead to censure from the European Court of Human Rights.
The German government has so far resisted reforms. In a parliamentary response last month, the Ministry of Labour argued that sheltered workshops provide “meaningful employment” for people who would otherwise be excluded from the workforce entirely. Critics dismiss this as paternalism. “It is not meaningful if you cannot afford to rent a flat or buy a winter coat,” said a spokesperson for the campaign group Equal Pay for Disabled Workers.
Money naturally is at the heart of the matter. Sheltered workshops generate billions of euros in revenue each year, often through contracts with major corporations for assembly and packaging work. Paying workers a living wage would eat into profits. A leaked internal report from the Federal Association of Sheltered Workshops estimates that fully equalising pay would increase operating costs by 40 percent.
The British example is not without its flaws. Campaigners point out that UK disabled workers still face a stubborn pay gap, with median earnings 15 percent below those of non-disabled colleagues. But the principle of equal pay for equal work is enshrined in law. In Germany, that principle does not exist for those with disabilities.
As the legal cases grind on, pressure is mounting on Berlin. The European Commission has launched a preliminary inquiry into Germany’s compliance with EU employment directives. And the UN Committee on the Rights of Persons with Disabilities is scheduled to review Germany’s record in 2025. For the 300,000 workers in sheltered workshops, the wait for justice has been long enough.
