Pay transparency in the Netherlands: what employers need to sort out now
Pay transparency for employers is quickly becoming more relevant for organisations in the Netherlands. The EU rules are already in place. What matters most for Dutch employers is this: the direction is set, but the final Dutch legislation isn’t finished yet. That makes it important to distinguish clearly between what is already officially settled and what is still being worked out in national law.
The basis is Directive (EU) 2023/970. According to the Dutch government’s Legislative Calendar (Wetgevingskalender), the final deadline for implementation is 7 June 2026. The same calendar also shows that the directive has not yet been fully implemented in the Netherlands.. The accompanying bill, the Wet implementatie Richtlijn loontransparantie mannen en vrouwen (Act implementing the Pay Transparency Directive for men and women), has been since 19 January 2026 with the Council of State.
Ondernemersplein (the Dutch government’s information portal for entrepreneurs) gives 1 January 2027 as the expected date for the Dutch law to take effect. It states clearly that this date isn't final, because the bill still has to be approved by the House of Representatives and the Senate. For employers, this means the exact Dutch details could still change, but the main lines are already clear enough to start preparing now.
What’s already settled?
Under the directive, applicants already have the right to information about the starting salary or salary range for a role. This information must be given in a way that allows an informed and transparent conversation about pay, for example in the job ad, before the interview or in another way in advance. Employers also may not ask applicants about their current or previous salary.In addition, job ads and job titles must be gender-neutral, and the recruitment process must be non-discriminatory .
There’s also a lot that’s already settled for employees. Employers must make the criteria for pay, pay levels and pay progression easily accessible. Employees also gain the right to request information in writing about their own pay level and about the average pay levels, broken down by gender,of colleagues doing the same work or work of equal value. Employers must remind employees of this right every year and provide the requested information within two months at the latest.
For larger employers, the directive also includes reporting obligations. Employers with 250 employees or more must also report by 7 June 2027 at the latest, and then every yearafter that. Employers with 150 to 249 employees must also report by 7 June 2027 at the latest, and then every three years. For employers with 100 to 149 employees the first report is due by 7 June 2031, and then every three yearsas well. The report must cover, among other things, the gender pay gap, median differences, variable pay, the distribution across pay quartiles and differences by category of employee.
If the report shows an average pay gap of at least 5% between women and men in a category of employees, and that gap can’t be justified on objective, gender-neutral grounds or corrected within six months, a joint pay assessment must be carried out with employee representatives.
What does this mean for employers in the Netherlands now?
In the internet consultation on the bill, the Dutch government has already made clear which way things are heading. According to the Rijksoverheid (the Dutch national government), employers will need to ensure objective pay structures, and be more open about salary and pay differences.They will no longer be allowed to ask about the last salary someone earned,and employers with more than 100 employees will have to report regularly on pay differences.
This means pay transparency isn’t just about the legal side of HR. It also affects how roles are valued, how salaries are built up, how job ads are written and how recruiters and hiring managers talk about terms of employment. Organisations that currently leave a lot of room for negotiation without a clear salary logic will increasingly need to be able to explain how pay is set. That need to explain is already built into the EU rules themselves.
A practical step-by-step plan for employers
1. Get clear on how salaries are currently set
For each role or job group, map out how the starting salary is determined, what the pay bands are and on what basis someone can progress. The directive requires these criteria to be objective and gender-neutral.
2. Set a starting salary or salary range for each role
Because candidates will have the right to information about the starting salary or salary range, it makes sense to have this clear up front. The directive doesn’t require it to always be in the job ad, but it does require that the information is available before the interview, or otherwise in good time.
3. Adjust your application process
Check your intake forms, interview formats and recruiter briefings. Questions about current or previous salary no longer fit within the directive’s rules. At the same time, check that job titles and job ads are gender-neutral and that the process is set up to be non-discriminatory.
4. Make pay criteria accessible internally
Employees should be able to easily find out what criteria are used to determine salary, pay scales and pay growth. That takes more than a policy. It also takes clear, accessible internal communication.
5. Set up a process for employee information requests
Employees will have the right to information about their own pay level and about the average pay levels for comparable roles. Employers must remind employees of this right every year and respond to a request within two months.
6. Prepare for reporting if your organisation has 100 or more employees
If you have 100 or more employees, it makes sense to start checking now whether the data you need is available, complete and reliable. The directive doesn’t just set out when reporting must happen. It also requires management to confirm the accuracy of the information, after consulting employee representatives.
The bottom line
What’s officially settled is clear. The EU directive is in place. Dutch implementation isn’t finished yet. At the same time, the main obligations are already clear to see: more openness about salary, objective and gender-neutral pay structures, no questions about salary history and additional reporting obligations for larger employers.
Employers don’t need to act as if every Dutch detail is already final. But waiting until the law is completely done isn’t the smartest move in practice. Now is the time to take a close look at your pay structures, recruitment processes and internal explanations. That’s where pay transparency starts in practice.
Getting ready for salary transparency?
Want to get clear on what pay transparency means for your vacancies, recruitment process and pay structure? Flexxy helps organisations make their hiring approach more practical, clearer and future-proof. From job profiles and salary ranges to job ads and recruitment processes, we’re happy to help you think it through.
Curious where your organisation stands right now? Get in touch with Flexxy for an exploratory conversation.