We, the German Women Lawyers Association (Deutscher Juristinnenbund, djb), welcome the initiative to adopt a new EUGender Equality Strategy.[1] We particularly support the general orientation of the Roadmap, adopted on 7 March 2025[2], especially its increased focus on intersectionality and the inclusion of new priority areas, such as health and education.
In light of the current backlash against gender equality across various parts of Europe, it is of particular importance to safeguard existing achievements. Under the von der Leyen I Commission, substantial progress has been made in key areas. These advances must not be jeopardized – on the contrary, imminent regressions must be actively countered and previous achievements defended.
In view of establishing the new EU Gender Equality Strategy, the Commission must ensure that the directives of the Gender Equality Acquisadopted in the last legislative period are implemented consistently, i.e. completely, correctly and within the specified deadline by the Member States. These include, in particular, the Directive on combating violence against women and domestic violence,[3] the Pay Transparency Directive,[4] the Directive for management positions[5] and the Reconciliation Directive[6], and the two Directives on standard for equality bodies.[7]
The European Commission must also take an active role in this regard, particularly by supporting implementation efforts within the Member States and by strengthening civil society actors.
Key instruments in this context include:
- the networking of relevant stakeholders,
- the exchange of best practices, and
- the provision of financial support for the implementation and further development of the Gender Equality Acquis. If necessary, the Commission should also use its legal instruments to enforce the correct application of the Gender Equality Acquis.
With this statement (while this list is in no way exhaustive), we wish to focus on several additional areas of concern and recommendations for the next Gender Equality Strategy:
- Strengthening gender mainstreaming, in particular through gender budgeting
- Integrating global perspectives, including feminist foreign policy into EU policies
- Addressing structural protection gaps in the labour market and private law
- Advancing gender-equitable data and digital policy
- Ensuring coordination of social security systems in the field of health care
- Consider and address the gender impacts of climate change.
A. Gender mainstreaming, in particular gender budgeting
I. Gender Mainstreaming
The Commission has committed itself to gender mainstreaming across major policy areas. We expressly welcome this commitment. However, the implementation of the proclaimed intentions is still a long way off in many policy areas and must be driven forward more strongly by the European Commission.
For example, the European Commission should include a gender perspective on rule of law indicators in its annual "Rule of Law Report " on the EU's preventive rule of law mechanism and the dialogue it initiates.
The Commission's report highlights developments in the Member States in four key areas of the rule of law: the judicial system, the anti-corruption framework, media pluralism and other institutional issues related to the separation of powers. Member States are required to report annually to the Commission on these four pillars. However, these indicators lack a gender-specific approach. In a consistent application of gender mainstreaming, the four pillars should also be viewed through the prism of gender equality policy within the framework of the rule of law mechanism and the active promotion of gender equality should be encouraged in all areas analysed.
II. Gender Budgeting and Financing in the New MFF
With a view to the upcoming Multiannual Financial Framework (MFF) post-2027, the new Gender Equality Strategy must reaffirm the binding application of gender budgeting across all EU funding programmes. While the current MFF proposal[8] references gender equality as a horizontal objective, it lacks concrete targets, ring-fenced funding, and measurable indicators, making effective implementation unlikely.
We therefore call on the European Commission to:
- ensure earmarked funding for gender equality programmes and women’s rights organisations, particularly within CERV+ and comparable instruments,
- provide institutional and long-term support to feminist and women-led civil society organisations, beyond project-based funding,
- introduce clear and measurable gender KPIs across all programmes to ensure transparency, accountability, and impact.
Only through targeted and structurally anchored funding can the goals of a sustainable, inclusive, and intersectional equality policy be realised.
B. Global perspectives
I. Bridging Global Funding Gaps as Part of a Coherent Feminist Foreign Policy
We welcome the inclusion of the Guide for EU External Action in the Roadmap and support its integration into the forthcoming Gender Equality Strategy. In light of the global feminist backlash, we urge the EU to uphold its international responsibility and to ensure that existing funding gaps in the field of gender equality are addressed in a sustained and strategic manner.
We emphasize, however, that a coherent and credible feminist foreign policy necessarily requires a consistent internal policy framework. This includes the targeted support of gender equality initiatives within Europe and the continued strengthening of a vibrant and independent civil society. Only if the EU sets clear internal standards can it credibly act as a global actor for gender justice.
II. "Sextortion" as a Gender-Specific Form of Corruption and Abuse of Power
Sextortion is a globally widespread criminal phenomenon that combines elements of corruption and abuse of power with sexual exploitation.[9] An illustrative example is the case of a woman in Uganda who complied with a prison official’s demand for sexual acts in order to obtain life-saving medication for her incarcerated husband.
Sextortion is a manifestation of structural power imbalances between the sexes, as women are disproportionately affected. The risk increases in times of multiple global crises and humanitarian emergencies.
Due to the specific nature of the offence, prosecution frequently fails: in many cases, neither anti-corruption laws nor sexual offence provisions are applicable. The phenomenon remains under-researched and has received limited public and legal attention to date.
We therefore recommend that the European Commission address the issue of sextortion in the upcoming Gender Equality Strategy. The goal should be to:
- improve the evidence base through research and data collection,
- identify gaps in protection, and
- develop proposals for a comprehensive legal framework, including, where necessary, specific (criminal law) provisions.
C. Gaps in Protection in the Labour Market and Private Law
I. Structural gender disparities in the workplace
The European Commission must ensure the comprehensive implementation of the Pay Transparency Directive so that the ongoing income disparity can be addressed. The reporting obligations are not fully implemented as of now, in part on the grounds of purported bureaucracy, which is not acceptable. Furthermore, we have developed a concept for a Flexible Working Time Act[10] which can function as a reference point for a legal framework for flexible working times across the EU, thus promoting the equitable sharing of care as well as employment responsibilities in families.
II. Protection from Violence
The EU should urge the remaining Member States to ratify the ILO Convention No. 190[11] and promote its domestic implementation. The protection against sexual harassment in the workplace provided by the Equal Treatment Directive should be extended to all civil legal relationships. It is not yet provided for by the Gender Equality in Goods and Services Directive and therefore does not extend to other contractual settings. However sexual harassment also occurs in access to and provision of goods and services.
III. Sustainability and Corporate Governance
The Corporate Sustainability Reporting Directive and the Corporate Sustainability Due Diligence Directive should be implemented in a gender-equitable and gender sensitive manner. This should be considered during the monitoring as well the reporting process pursuant to Article 6 CSRD.
D. Gender-equitable data and digital policy
I. Protection from Violence
The combating of gender-based violenceonline, including better documentation, should be further promoted. This concerns the introduction of appropriate provisions in consumer and data protection law and cyber-security.
The following gaps in protection should inter alia be addressed: domestic violence via the use of smart (home) devices, image-based digital violence including deep fakes; silencing women which aims at preventing their democratic participation in public discourse and politics.
II. Resources
The EU has committed itself too actively shaping Europe's digital future and has adopted a set of important legislative acts (AI-regulation[12], digital market act[13] and digital services act[14]). Nevertheless, also taking into account the fast technical developments and new scientific findings, an evaluation and possible revision of the implementation of notably the AI-Act should be envisaged. The regulation does not sufficiently address data quality and is not legally binding regarding the adherence to codes of conduct. For example, Gender-sensitive training of AI and monitoring of data sets, especially regarding the prevalence of misogynistic and antifeminist content, should be a key concern. Furthermore, the AI-Act does not prohibit so called “high risk” applications and therefore does not confer effective protection from inter alia gender-based discrimination.
Educational measures should promote the acquisition of digital skills among girls and women (‘Digital Gender Gap’), and STEM support programmes for women should be supplemented by programmes to ensure socio-technical and gender competence.
Bridging the Gender Data Gap in digital healthservices by promoting gender-sensitive medical science is also critical.
E. Coordination of social security systems in the field of health care
I. Ensuring Minimum Standards in Women’s Health Care Across Europe
The new Gender Equality Strategy should explicitly address the need to establish and uphold minimum standards for women's healthcare across all EU Member States. Equal access to essential health services is a cornerstone of gender equality. However, considerable disparities persist in the availability, affordability, and legal accessibility of sexual and reproductive health services, particularly with regard to access to safe and legal abortion.
A gender-equal Europe cannot exist without ensuring that all women, regardless of their residence status or nationality, can effectively exercise their reproductive rights. In this context, special attention must be paid to asylum seekers and migrant women, who frequently face multiple barriers to care due to administrative restrictions, lack of information, legal uncertainty, and discrimination.
We call on the European Commission to:
- include a commitment to harmonised health care standards for women in the upcoming Gender Equality Strategy,
- recognize access to safe abortion as a matter of fundamental rights and bodily autonomy, and
- ensure that health care entitlements within asylum systems are gender-sensitive, non-discriminatory, and explicitly include access to reproductive health care.
A Union based on equality must not tolerate situations where a woman’s access to basic medical care depends on her country of origin, migration status, or the legal regime of the host Member State.
II. Social security for cross-border care work
By 2070, 30% of the EU population will be over 65 years old and the number of people in need of care will rise to 23.6 million.[15]The care work that will be required as a result will increasingly be provided across borders by carers and care assistants, creating chains of care that are unevenly distributed according to the level of prosperity of the Member States. The Posting of Workers Directive[16] already guarantees posted care workers, most of whom are women, a wage at the level of the place of employment, although it is virtually impossible to monitor compliance in private households. However, carers are referred to their country of origin for social security. Due to the low level of social security and the lack of monitoring of this security, transnational carers are disadvantaged and completely inadequately covered in the event of pregnancy, maternity, illness, disability and old age. The European Commission should address this important issue and work towards a comprehensive concept to regulate transnational care work as a separate sector outside the Posting of Workers Directive, in order to guarantee social security for all care workers at the level of their place of employment.
F. Gender impacts of climate change
We welcome the European Commission's recognition of the importance of gender equality in the fight against climate change. In particular women play a key role in this fight (as agents of change). They are at the forefront of efforts to combat climate change and harmful behavior, spearheading global and national climate movements and playing a pivotal role in promoting change as consumers, workers, and politicians.
Nevertheless, women and other marginalized groups are unfortunately also disproportionately affected by the negativeconsequences of climate change. This is because the climate crisis has gender-specific effects, arising from various discriminatory societal structures. For instance, extreme weather events such as floods, hurricanes and heatwaves frequently result in significantly more deaths among women and other marginalized groups than among men.
Without effective action to combat the root causes of climate change, it would be considerably more difficult to realize the other goals of the Gender Equality Strategy, particularly the right to the highest attainable standard of physical and mental health.
We therefore call on the European Commission:
- to give prominence to the dangers posed by climate change in the EU Gender Equality Strategy,
- to consistently consider the impact of climate change on women and other marginalized groups in all policy areas of the EU Gender Strategy, and
- to take decisive action in the fight against climate change, both in Europe and globally.
Ursula Matthiessen-Kreuder
President
Valentina Chiofalo
Chair of the Commission on European and International Law
[1] This statement was published on 11 August 2025 here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14611-Gender-Equality-Strategy-2026-2030/feedback_en?p_id=56997442.
[2] See “djb macht Druck für Gleichstellung in Europa“, https://www.djb.de/presse/pressemitteilungen/detail/pm25-33.
[3] Directive (EU) 2024/1385 of 14 May 2024 on combating violence against women and domestic violence, OJ L2024/1385, available at: https://eur-lex.europa.eu/eli/dir/2024/1385/oj/eng (Directive on combating violence against women and domestic violence).
[4] Directive (EU) 2023/970 of 10 May 2023 on strengthening the application of the principle of equal pay for men and women for equal work or work of equal value through pay transparency and enforcement mechanisms, OJ L132/21, available at: https://eur-lex.europa.eu/eli/dir/2023/970/oj (Pay Transparency Directive).
[5] Directive (EU) 2022/2381 of 23 November 2022 on ensuring a balanced representation of women and men among the directors of listed companies and related measures, OJ L315/44, available at: https://eur-lex.europa.eu/eli/dir/2022/2381/oj (Directive for management positions).
[6] Directive (EU) 2019/1158 of 20 June 2019 on work-life balance for parents and carers and repealing Council Directive 2010/18/EU, OJ L188/79, available at: https://eur-lex.europa.eu/eli/dir/2019/1158/oj (Reconciliation Directive).
[7] Directive (EU) 2024/1499 and Directive (EU) 2024/1500.
[8] Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing Global Europe, COM/2025/551 final.
[9] This does not refer to online sexual extortion or blackmail, but to cases where sexual acts are demanded in exchange for the performance of official duties.
[10] Available at https://www.djb.de/fileadmin/user_upload/160227_WAZG_Konzeption.pdf.
[11] See for more details djb Policy Paper of 12 September 2024 “Implementation of the ILO Convention against Violence and Harassment in the World of Work (No. 190)”, available at https://www.djb.de/presse/pressemitteilungen/detail/st24-32#_ftn22.
[12] Regulation (EU) 2024/1689.
[13] Regulation (EU) 2022/1925 of 14 September 2022 on contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828, available at: http://data.europa.eu/eli/reg/2022/1925/2022-10-12 (Digital Markets Act).
[14] Regulation (EU) 2022/2065 of 19 October 2022 on a single market for digital services and amending Directive 2000/31/EC, OJ L277, 1, available at: http://data.europa.eu/eli/reg/2022/2065/2022-10-27.
[15] Nicolas Schmit, Europe's social market economy in transition, SRa 2022, 210.
[16] Directive 96/71/EC of 16 December 1996 concerning the posting of workers in the framework of the provision of services, OJ L18, 1, available at: https://eur-lex.europa.eu/eli/dir/1996/71/2020-07-30.
