Salary transparency in the Netherlands: What employers need to regulate now

Salary transparency for employers is a topic that is rapidly becoming more relevant for organisations in the Netherlands. The European rules are already in place. What matters most to employers in the Netherlands is this: the direction is fixed, but the final Dutch legislation has not yet been finalised at this point. This makes it important to distinguish carefully between what is already officially fixed and what is still being worked out in national legislation.

The basis is Directive (EU) 2023/970. According to the Legislative Calendar, the implementation deadline is 7 June 2026. The same Legislative Calendar also states that the directive in the Netherlands is still has not been fully implemented. The accompanying bill, the Act implementing Gender Pay Transparency Directive, has been located since 19 January 2026 in the phase Council of State.

Entrepreneurs' Square mentions 1 January 2027 as the expected effective date of the Dutch law change. It explicitly states that that date is still not final is, as the bill still has to be adopted by the Lower and Upper Houses first. For employers, this means that the exact Dutch elaboration may still change, but the outlines are already clear enough to start preparing now.

What is already fixed?

For job applicants, the directive already establishes their right to information about the starting salary or salary range of a position. That information should be given in such a way that an informed and transparent conversation about salary is possible, for instance in the job posting, before the interview or in some other way beforehand. Employers may additionally not asking about their current or previous salary. Also, vacancies and job titles should gender-neutral be and the recruitment process should non-discriminatory expire.

For employees, too, much is already fixed. Employers need to define the criteria for reward, remuneration levels and remuneration development easily accessible. Employees will also be given the right to request information in writing about their own remuneration level and on the average pay levels broken down by gender, from colleagues doing the same or equivalent work. Employers should give employees there annual point out and provide the requested information no later than within two months provide.

For larger employers, the directive also includes reporting requirements. Employers with 250 employees or more must be done no later than 7 June 2027 report and then annual. Employers with 150 to 249 employees must be done no later than 7 June 2027 report and then once every three years. For employers with 100 to 149 employees first report applies no later than 7 June 2031, then also once every three years. That reporting should include gender pay gap, median differences, variable pay, distribution across pay quartiles and differences by employee category.

Does that report show an average pay gap of at least 5% exists between women and men, and that difference cannot be justified objectively and gender-neutrally, nor within six months be restored, then a joint remuneration review take place with employee representatives.

So what does that mean for employers in the Netherlands?

The Dutch government has already made it clear in the internet consultation on the bill which way it is going. According to central government, employers must ensure objective wage structures, become more open about salary and wage differentials, they may no longer ask for the last-earned salary, and employers need to come up with more than 100 employees periodic reporting on wage differentials.

With that, salary transparency does not just touch the legal side of HR. It also touches the way jobs are valued, how salaries are built up, how vacancies are written and how recruiters and hiring managers have the conversation about terms of employment. Organisations that currently leave a lot of room for negotiation without clear salary logic will need to be increasingly able to explain how pay is arrived at. That requirement of explainability is already built into the European rules themselves.

A practical roadmap for employers

1. Clarify how salaries are now determined
For each job or job group, map out how the starting salary is determined, the ranges and the criteria for someone to progress. The guideline requires those criteria to be objective and gender-neutral.

2. Set a starting salary or salary range for each role
Because candidates will be entitled to information about the starting salary or salary range, it is wise to have this clear in advance. The guideline does not prescribe that this must always be in the job posting, but it does require that this information be available before the interview or otherwise in good time.

3. Adapt the application process
Check intake forms, interview formats and recruiter briefings. Questions about current or previous salary no longer fit within its rules. At the same time, check that job titles and vacancies are gender-neutral and that the process is designed to be non-discriminatory.

4. Make remuneration criteria internally accessible
Employees should be able to easily retrieve the criteria by which salary, pay scales and salary growth are determined. This requires not only policy, but also clear and accessible internal communication.

5. Set up a process for employee information requests
Employees will be entitled to information on their own pay levels and on average pay levels of comparable positions. Employers must inform employees of this right annually and respond to a request within two months.

6. Prepare reporting if your organisation has 100 or more employees
For employers of 100 or more employees, it is wise to check now whether the necessary data is available, complete and reliable. The directive not only prescribes when reporting must take place, but also that the accuracy of that information must be confirmed by management, after consultation with employee representatives.

The core

What is now officially established is clear. The EU directive is there. The Dutch implementation has not yet been finalised. At the same time, the main commitments are already clearly visible: greater pay disclosure, objective and gender-neutral pay structures, no questions about salary history and additional reporting requirements for larger employers.

So employers do not yet have to pretend that every Dutch detail rule is already finalised. But waiting until the law is completely finalised is practically not the smartest route. Right now is the time to hold salary structures, vacancy processes and internal explanations up to the light. That is where salary transparency starts in practice.

Getting ready for salary transparency?

Do you want to get a sharp focus on what salary transparency means for your vacancies, recruitment process and pay structure? Flexxy helps organisations make their hiring approach more practical, clear and future-proof. From job profiles and salary grades to vacancy texts and recruitment processes: we are happy to think along with you.

Wondering where your organisation stands now? Contact Flexxy for an exploratory discussion.