On March 28, 2025, the Netherlands released draft amendments to the Equal Treatment of Men and Women Act, transposing the EU Pay Transparency Directive. These changes introduce both transparency and reporting obligations, with full adoption expected ahead of the June 7, 2026 transposition deadline.
Currently, the Netherlands has no mandatory gender pay gap reporting, but this will change under the Directive. Employers should begin preparing for new transparency and reporting requirements based on employer size.
Netherlands reporting requirements
Who needs to report?
Under the draft law:
- 250+ employees: annual reporting, first by June 7, 2027 (2026 data)
- 150–249 employees: reporting every three years, first by June 7, 2027
- 100–149 employees: reporting every three years, first by June 7, 2031
- Fewer than 100 employees: not subject to reporting under the current draft
What to report?
Employers must include both overall and category-of-worker gender pay gaps:
- Mean and median gender pay gaps for total and complementary/variable pay
- Proportions of men and women receiving variable pay
- Gender distribution across pay quartiles
- Pay gap analysis by job category (same work or work of equal value)
If a pay gap of 5% or more is identified and unjustified, employers are required to conduct a Joint Pay Assessment with worker representatives within six months.
Where and when to report?
Regulatory Filing
Employers must submit reports to a designated administrative body, the Netherlands Labour Authority (Nederlandse Arbeidsinspectie), which will publicly publish pay gap results and maintain them for up to four years.
Internal & Public Disclosure
Employers must certify data accuracy, consult works councils, and share key findings and remediation plans with employees and the public.
Deadlines and Cadence
Annual or triennial reporting as per employee thresholds.
Netherlands pay transparency requirements
Transparency obligations apply to all employers, regardless of size, and include:
- Salary range disclosure in job ads or before interviews
- Salary history ban during recruitment
- Pay structure access: employees can request written information on pay criteria and progression; 50+ employers must publish these processes
- Right to pay data: employees may request average gender pay data on work of equal value to their position in writing, to be returned within two months
Employment equity standards
The Equal Treatment of Men and Women Act already prohibits gender-based pay discrimination. The draft amendments strengthen legal obligations by mandating clear, objective, transparent pay systems and accountability.
The risks of non-compliance
The draft legislation introduces:
- Employers who fail to meet key obligations may be subject to fines imposed by the Netherlands Labour Authority, which must be effective, proportionate, and dissuasive.
- Reversal of burden of proof: In legal proceedings, once the employee presents facts suggesting discrimination, the employer bears the burden of proving that no discrimination occurred.
- Certification and consultation requirements, increasing reputational and administrative risk.
Netherlands’ proposed EU Directive legislation
The draft fully aligns with the Directive, including:
- Clear reporting thresholds and timelines
- Required pay gap metrics and Joint Pay Assessment rules
- Robust transparency frameworks and rights
- Administrative oversight and enforcement mechanisms.
Final legislation is expected before June 7, 2026, with phased reporting beginning in June 2027.
How Trusaic helps employers comply with Netherlands requirements
1. Comply – Use RAPTR™ to complete required reporting by compliance deadlines.
Stay ahead of evolving regulations with Trusaic’s Regulatory Pay Transparency Reporting™ solution, designed to help you determine applicability, meet deadlines, and submit compliant reports across EU jurisdictions with the click of a button.
Our Pay Equity Software Suite ensures your pay systems are legally defensible, gender-neutral, and future-proof — automating complex reporting and enabling GDPR-compliant data sharing through certified integrations with major HCM platforms.
2. Correct – Use PayParity® to understand, explain and resolve pay disparities.
Use PayParity to identify, explain, and resolve pay disparities across gender, race, age, and more. Whether you’re conducting proactive assessments or responding to compliance triggers like the EU Directive’s Joint Pay Assessment requirement, PayParity delivers defensible, data-driven insights. Our Remediation Optimization Spend Agent (R.O.S.A.) works as PayParity’s AI remediation partner to ensure you lower your pay gap below 5% while maximizing the ROI of your remediation budget.
3. Communicate – Use the Pay Equity Product Suite to communicate narratives and share salary ranges with confidence.
Comply confidently with the EU Directive’s pay range transparency mandates using Trusaic’s Salary Range Finder, which provides data-driven guidance for equitable pay ranges that can be shared with candidates and employees.
Our Pay Transparency Agent answers reporting questions instantly, and our Communications Agent crafts context-specific narratives — in any language — to support your public disclosures and internal communications.
How to Prepare to Comply with the EU Directive
The EU Pay Transparency Directive, approved in 2023, gives Member States until June 7, 2026 to transpose its provisions. The Netherlands must adopt these requirements into law by that deadline.
Employers in the Netherlands should begin preparing now by:
- Conducting pay audits and internal assessments
- Reviewing compensation structures and job architecture
- Preparing HR and legal teams for employee data requests
- Updating hiring practices to comply with upcoming salary posting and history ban requirements
Trusaic is GDPR compliant and can support organizations operating in any EU Member State with both EU Pay Transparency Directive and EU Corporate Sustainability Reporting Directive obligations.
FAQs
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Who is required to submit gender pay gap reports in the Netherlands?
Employers with 100 or more employees must submit gender pay gap reports under the proposed legislation. Reporting obligations begin in 2027 for companies with 150 or more employees and in 2031 for those with 100–149 employees. Employers with fewer than 100 employees are not subject to the reporting requirement under the current draft.
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What specific data must be included in the gender pay gap report?
Employers must report the mean and median gender pay gaps for both total and variable pay, gender distribution across pay quartiles, and the proportion of men and women receiving variable compensation. Pay gap metrics must also be provided by job category for same or comparable work.
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What happens if a 5% or greater gender pay gap is found?
If a pay gap of at least 5% exists within a job category and cannot be justified, employers are required to conduct a Joint Pay Assessment with worker representatives within six months.
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Where do reports need to be filed?
Reports must be submitted to the Netherlands Labour Authority (Nederlandse Arbeidsinspectie), which will publish the results and maintain them for up to four years.
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Are employers required to disclose pay information internally?
Yes. Employers must certify the accuracy of their reports, consult works councils, and share key findings and remediation measures with employees.
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What are the salary transparency requirements for job postings and recruitment?
All employers, regardless of size, must either include a salary range in job postings or disclose it before an interview. They are also prohibited from asking applicants about salary history.
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Do employees have the right to request pay information?
Yes. Employees can submit a written request to access average gender pay data for roles of equal or comparable value. Employers must respond within two months.
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What are the consequences for non-compliance?
Non-compliance may result in fines issued by the Labour Authority. The legislation also introduces a reversal of the burden of proof in legal proceedings, placing the responsibility on employers to demonstrate the absence of discrimination.
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What is the timeline for implementation?
Final legislation is expected by June 7, 2026. Reporting requirements will begin in 2027 for larger employers and phase in for smaller employers by 2031.