EU Pay Transparency Directive Status Netherlands: Missed: Targeting 2027
An initial draft of the Dutch Pay Transparency Act was published on 27 March 2025. On 15 September 2025, the government announced it would delay implementation for employers with 150 or more employees to 1 January 2027, and a revised version of the bill was submitted to the Council of State (Raad van State) on 19 January 2026 for review. The Council published its advisory opinion on 1 April 2026, explicitly noting that the proposed timeline does not meet the 7 June 2026 EU deadline. Before the deadline passed, the government had said it still expected the legislation to be finalised by 7 June 2026, but that did not happen, and the Netherlands is now one of 23 EU member states that missed the deadline. The bill still needs to pass through both the Tweede Kamer (House of Representatives) and the Eerste Kamer (Senate) before it can become law. Because the bill has not yet been passed, the reporting thresholds, data points and enforcement mechanics below reflect the draft as it currently stands and could still change during parliamentary debate; employers should treat them as the best available indication rather than final law.
What is Pay Transparency, and who does it apply to?
The EU Pay Transparency Directive (Directive (EU) 2023/970) is a binding EU law requiring pay equity for equal work between women and men. It introduces mandatory rules around salary disclosure, pay gap reporting, and worker rights.
The Netherlands currently relies on the Equal Treatment of Men and Women Act to prohibit gender-based pay discrimination, but has no mandatory gender pay gap reporting regime today. The Netherlands missed the 7 June 2026 EU-wide transposition deadline for the Pay Transparency Directive, and the implementation bill is still working through the legislative process, with the government now targeting an entry into force around 1 January 2027.
Under the draft bill, mandatory gender pay gap reporting would apply from 100 employees upward, with annual reporting for employers of 250 or more and reporting every three years for those with 100 to 249 employees, while publishing pay-setting processes would apply from 50 employees, and baseline salary range disclosure and the salary history ban would apply to all Dutch employers regardless of size; none of these thresholds are final law yet.
What employers must do in Netherlands
All employers, regardless of size (proposed, not yet law)
- Disclose salary ranges in job postings or before interview
- Refrain from asking candidates about salary history
- Allow employees to request written information on pay-setting criteria and pay progression processes
- Respond to a worker's request for average gender pay data on work of equal value within two months
Employers with 50 or more employees (proposed)
- Publish the pay-setting and pay-progression processes, rather than only providing them on request
Employers with 100 to 149 employees (proposed)
- Report gender pay gap data every three years, with a first deadline of 7 June 2031 covering 2030 data
Employers with 150 to 249 employees (proposed, subject to the announced delay to 2027)
- Report gender pay gap data every three years, with a first deadline of 7 June 2027 covering 2026 data
Employers with 250 or more employees (proposed)
- Report gender pay gap data annually, with a first deadline of 7 June 2027 covering 2026 data
- Report mean and median pay gaps for total and variable pay, the proportion of men and women receiving variable pay, pay quartile distribution, and pay gaps by job category
- Conduct a Joint Pay Assessment with worker representatives within six months if an unjustified pay gap of 5% or more is identified
- Certify the accuracy of reported data, consult works councils, and share findings and remediation plans with employees and the public
Key deadlines
Penalties for non-compliance in Netherlands
The draft bill provides for fines imposed by the Netherlands Labour Authority that must be effective, proportionate and dissuasive, but specific euro amounts have not yet been fixed in the legislation; a reversal of the burden of proof in pay discrimination claims, shifting it onto the employer once an employee presents facts suggesting discrimination, is a confirmed feature of the proposal.
Once enacted, the law designates the Netherlands Labour Authority (Nederlandse Arbeidsinspectie) as the body responsible for receiving reports, publishing results, keeping them publicly available for up to four years, and enforcing compliance.
How TalentUp can help you with Pay Transparency Compliance
Below you can see a preview of our platform, where we help you stay compliant with Pay Transparency by spotting pay inconsistencies and structural risks in your compensation strategy, analysing data from your company.
Book a demo| Name | Level | Location | Salary | Labels | Actions |
|---|---|---|---|---|---|
|
John Doe
Software Developer
|
Mid
|
Amsterdam
Netherlands
|
32500 EUR
Above market
|
Unbalanced
|
|
|
Jane Smith
Project Manager
|
Senior
|
Amsterdam
Netherlands
|
45000 EUR
Above market
|
In Market
|
|
|
Michael Brown
Data Analyst
|
Mid
|
Rotterdam
Netherlands
|
39000 EUR
Above market
|
In Market
|
|
|
Emily Johnson
QA Engineer
|
Mid
|
Rotterdam
Netherlands
|
36000 EUR
Above market
|
In Market
|
|
|
Robert Wilson
HR Manager
|
Senior
|
The Hague
Netherlands
|
50000 EUR
Above market
|
Above Market
|
|
|
Sarah Davis
Marketing Specialist
|
Junior
|
The Hague
Netherlands
|
34000 EUR
In market
|
In Market
|
MEAN PAY
39.4K EUR
MEDIAN PAY
37.5K EUR
MEAN FEMALE PAY
38.3K EUR
MEDIAN FEMALE PAY
36K EUR
MEAN MALE PAY
40.5K EUR
MEDIAN MALE PAY
39K EUR
Gender gap
Variable pay by gender
General gender pay gap
Pay gap insights
Add employee data to see pay gap insights
Tenure distribution
Pay gap per level (quartiles)
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Frequently asked questions about pay transparency in Netherlands
No, not as final law. The Netherlands missed the 7 June 2026 EU deadline, and the implementation bill is still moving through the Dutch parliament, with entry into force targeted around 1 January 2027.