Pay Transparency TrackerEU Directive 2023/970 · 27 member statesNetherlands
ConsultationNetherlands
Council of State issues advice W12.26.00016/III on the draft implementation bill
The Advisory Division of the Council of State issued advice W12.26.00016/III on the draft Wet implementatie Richtlijn loontransparantie mannen en vrouwen. The advice was established on 1 April 2026, with the Wetgevingskalender milestone Advies Raad van State uitgebracht recorded on 2 April 2026, the Raad van State publishing the advice on its own portal on 7 April 2026, and the Wetgevingskalender publishing the document on 10 April 2026. The Council criticises the proposed delayed first pay, reporting deadline of 7 June 2028 for employers with 150 or more employees, stating that the Directive requires the first report by 7 June 2027 and leaves no room for the proposed later date. It also asks for clearer justification of the administrative burdens, clearer assignment of the monitoring body, and clarification on gender registration and privacy issues, and advises taking these comments into account before submission to the Tweede Kamer. Earlier: 2026, 01, 19, Draft bill and explanatory memorandum submitted to the Council of State.
The situation in the Netherlands regarding pay transparency is currently characterized by a series of legislative steps. A draft implementing pay transparency and reporting requirements was issued by the Dutch Government on 25 March 2025, followed by the parliament's review of amendments to the Equal Treatment Act in March 2025, indicating ongoing discussions in this area. Several accounts indicate that the draft legislation has experienced delays, suggesting a complex legislative process. There is a consensus regarding the proposed implementation date, which has been pushed further into the future as the parliamentary discussions continue, highlighting the evolving nature of this initiative. While some accounts mention the anticipated implementation date being extended with a possible public consultation being held around December 2025, others note specific legislative activities occurring as late as June 2026. This divergence reflects the uncertainty and varying expectations surrounding the finalization and execution of the pay transparency measures.
Sources- click to expand
- Syndio , EU Pay Transparency Directive Transposition Tracker· synd.io· viewed 2026, 06,
- Taylor Wessing , Equal Pay Tracker· taylorwessing.com· viewed 2026, 06,
- Pinsent Masons , EU Pay Transparency Directive in EU Member States· pinsentmasons.com· viewed 2026, 06,
- L&E Global , Pay Transparency Directive posts (search feed)· leglobal.law· viewed 2026, 06,
- Figures , European Pay Transparency Directive Tracker· figures.hr· viewed 2026, 06,
- PayGap , Pay Transparency Legislation Tracker· paygap.com· viewed 2026, 06,
- beqom , EU Pay Transparency Directive Transposition by Country· beqom.com· viewed 2026, 06,
- Mirro , Timeline and Compliance Checklist for EU Pay Transparency Directive· mirro.io· viewed 2026, 06,
Recent external coverage of pay transparency transposition. Not confirmed legal status.
- Dutch cabinet scrapped AOW plan, raising concerns about pay transparencySalarisNet · 4 Jun 2026
This article discusses concerns over pay transparency in the context of the government's decision, making.
- ‘Being open about salaries leads to more trust’: Entrepreneurs on pay transparencyIntermediair · 1 Jun 2026
The article explores how transparency can foster greater trust in employer, employee relationships.
Legislative Aspects & Gap Analysis
Research in progressNational implementing measures for Directive (EU) 2023/970 are published on EUR-Lex once a country adopts transposing legislation.
Comparison showing prior national law, EU directive requirements, and national transposition status.
This summary is generated by AI from public sources and has not been reviewed by legal experts. Use it as a starting point for further verification, not as legal advice.
| Aspect | Prior National Law | EU Directive | National Transposition |
|---|---|---|---|
Whom This Concerns | TBD | TBD | TBD |
Recruiting | TBD | TBD | TBD |
Job Classification | TBD | TBD | TBD |
Compensation Structure | TBD | TBD | TBD |
System Design | TBD | TBD | TBD |
Pay Progression | TBD | TBD | TBD |
Collective Agreements | TBD | TBD | TBD |
Employee Rights | TBD | TBD | TBD |
Reporting | TBD | TBD | TBD |
Gap Analysis | TBD | TBD | TBD |
Participation | TBD | TBD | TBD |
Penalties | TBD | TBD | TBD |
Support | TBD | TBD | TBD |