AI AND WOMEN’S LABOUR RIGHTS: GENDER PAY TRANSPARENCY IN GERMANY AND UZBEKISTAN

Аннотация

This article examines how the use of artificial intelligence in pay-setting affects women’s right to equal pay and how pay transparency legislation can protect against algorithmic pay discrimination. The German model, based on the Pay Transparency Act of 2017, Directive (EU) 2023/970 and the Artificial Intelligence Act, is compared with the Uzbek model, based on the Constitution, the Labour Code, the Law “On Guarantees of Equal Rights and Opportunities for Women and Men”, the Law “On Personal Data” and Law No. ZRU-1115 of 21 January 2026. It is shown that algorithmic tools for setting salaries, bonuses and performance ratings can reproduce historical pay gaps and conceal them behind technical opacity, and that safeguards aimed only at exclusively automated decisions are of limited use in pay matters. The gaps in Uzbek legislation are identified, and proposals are formulated for introducing a pay transparency regime adapted to the use of artificial intelligence.