Netherlands

The legislative text (Pay Transparency Act) and Explanatory Memorandum was published by the Dutch government on 21 May 2026 and has been submitted to the House of Representatives. As part of the legislative process, further amendments to the legislative proposal may still be introduced. On 19 June 2026, the Dutch government published a further draft decree for consultation (Besluit implementatie Richtlijn loontransparantie mannen en vrouwen). The decree elaborates on key provisions of the proposed Pay Transparency Act, including pay concepts, the gender pay gap formula, reporting deadlines, agency workers, publication of inspection data, and electronic filing. The consultation closed on 31 July 2026. On 2 September 2026, the Dutch Minister of Social Affairs and Employment published a general parliamentary memorandum on the draft legislative proposal. Between 9 July 2026 and 11 September 2026, a separate consultation took place on the Regulation on the Implementation of the Equal Pay Transparency Directive for Men and Women (Regeling implementatie Richtlijn Loontransparantie mannen en vrouwen) concerning the definitions and calculation methodologies for pay reporting and including a draft reporting template intended to provide guidance on the preparation and submission of pay reports. The Dutch government initially indicated that the new legislation would enter into force by 1 January 2027. However, it has recently been confirmed that the draft implementation legislation is scheduled for plenary debate at the House of Representatives during the week commencing 11 January 2027. As a result, the proposed implementation deadline of 1 January 2027 will no longer be achievable. The Dutch government has further confirmed that employers with 150 employees or more must report for the first time by 7 June 2028, covering the calendar year 2027 (reporting annually if 250 or more employees, and every 3 years if 150–249 employees). Employers with between 100 and 150 employees must submit their first report by 7 June 2031 at the latest, covering the calendar year 2030 (reporting every 3 years). Whilst the exact implementation date remains uncertain and will depend on the progress of the parliamentary process, the publication of the draft legislation, and the subordinate regulations means that the key rules, definitions, and implementation framework are now available. Employers therefore have sufficient information to continue preparing for compliance with the Directive, even though certain aspects may still be amended during the legislative process.