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Pay Transparency: 1 January 2027 Implementation Deadline May Not Be Achievable, but Preparing Remains Prudent

Employment, Employee Participation & Mediation

28 September 2026

Written by

Thomas Catersels

Barbara van Dam

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At the beginning of September, the Dutch government indicated that implementing the new pay transparency rules by 1 January 2027 would be feasible. That date now appears less certain. According to the Dutch House of Representatives’ current schedule, the bill is not due to be debated in plenary until the second week of 2027. Both the House of Representatives and the Senate will then still need to consider the proposal. As a result, entry into force on 1 January 2027 no longer appears likely.

Why Start Preparing Now?

Uncertainty surrounding the implementation date does not mean that employers should simply wait and see. On the contrary, now is a good time to assess how prepared the organisation is for the new obligations and to begin making the necessary preparations. In our earlier blog posts, Pay Transparency: A Good Idea… but Does It Work in Practice? and Pay Transparency Legislation: Potential Changes for Works Councils, we discussed the importance of timely, coordinated efforts by the management board and works council (ondernemingsraad, or OR), ensuring that strategy, employee representation and implementation are aligned.

Key Considerations for Employers

Consider, among other things, the following questions:

  • Map your pay data. Identify where information on salaries, bonuses and other pay components is recorded within the organisation, and whether these data are up to date and complete.
  • Assess the robustness of your remuneration policy. Review how salary grading and pay progression are currently determined and whether these practices are likely to withstand scrutiny under the new pay transparency rules.
  • Review your job classification system. For example, determine whether your job evaluation and classification system is based on objective, gender-neutral criteria and whether this can be adequately demonstrated.
  • Prepare the organisation for transparency towards current and prospective employees. Consider both recruitment and selection processes and how requests from employees for information about pay will be handled.
  • Involve the works council at an early stage. Determine the role of the works council or other employee representatives in remuneration policy and involve them in the preparations in good time.

Preparation Pays Off, but Acting Too Soon Does Not Always Help

Although the main principles of the new rules are known, definitive requirements are still lacking in certain areas. Employers would be well advised to make the necessary preparations, but should consider postponing final decisions on the design of internal processes and supporting systems until the full set of rules has been clarified.

Conclusion: Start by Gaining Insight, but Wait Before Finalising Implementation

The implementation date for the pay transparency rules may be uncertain, but preparations need not be. Employers would be well advised to review their remuneration policies and job classification arrangements against the principles already established in the proposed legislation. Identify potential issues, but wait until the legislation has been finalised before making definitive changes to systems and processes. By gaining a clear understanding of the areas requiring attention now, employers can avoid unwelcome surprises when the new rules come into force.

Questions?

If you have any questions, please contact Barbara van Dam or Thomas Catersels from our Employment Law & Employee Participation team.

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