The Netherlands: The EU Pay Transparency Directive
Published on 3rd September 2025
Details on the process of implementation of the Directive in the Netherlands
What is the current implementation status and timing?
The Directive has not yet been implemented in the Netherlands. A first draft of the proposal has been published. Implementation will take effect immediately after the legislative process has been completed. It is expected that the legislative proposal will be force in 2026.
Which workers are in scope?
It is anticipated that national laws will align with the Directive definition of a worker requiring the existence of an employment contract or employment relationship defined by law, collective agreements, or practice in force in that Member State. It will likely include part-time, fixed-term, temporary agency workers, managers; and where criteria are met, atypical workers (e.g. zero hours, trainees, apprentices, platform workers).
Who will be worker representatives?
We are awaiting further details of implementing legislation.
Are there any proposals around the methodology and tools for assessing "equal value"?
The requirements imposed by the Directive mean that job grading systems will change. The works council has a right of consent regarding job-grading systems.
How is pay defined?
It is unclear whether legislation will clarify what pay elements are included and excluded from the definition of pay. No draft legislative proposal is currently available.
How are the requirements for transparency for job applicants being implemented?
We are awaiting further details of measures to be introduced to align with the Directive.
- Click here for current position
Currently, all recruitment processes must be conducted in a non-discriminatory manner. There is a general prohibition on unequal treatment when offering a job and handling the filling of a vacancy, employment services and entering and terminating an employment relationship; employers may not therefore discriminate on the basis of certain grounds for discrimination. Acting in violation of this legislation is prohibited and may result in unlawful conduct (damage claim).
How are the requirements for transparency for workers being implemented?
We are awaiting further details of measures to be introduced to align with the Directive.
How are the gender pay reporting requirements being implemented?
It is currently unknown if legislation bringing the Directive requirements into force will lower the threshold numbers for reporting or bring forward the deadlines for initial reporting and/or provide for greater frequency of reporting.
When counting workers for the purposes of the Directive's pay reporting thresholds, will only workers of a particular "legal entity" be in scope?
There is no definitive answer at present.
Do we have details on how the requirements for a joint pay assessment will be implemented?
We are awaiting further details.
Do we have details as to how the Directive obligations will be enforced and potential sanctions?
We are waiting for further details of measures to align with the Directive.
Are there any tools or guidance available to support employers?
The Ministry of Social Affairs and Employment (with the social partners) will develop methods and tools to establish pay structures and support reporting. It is expected that these tools will be released ahead of legislation implementing the Directive coming into force.
Return to main EU Pay Transparency Directive page
