The Dutch government has confirmed a delay in implementing the EU Pay Transparency Directive.

The new law will be coming into force no later than 1 January 2027. This means:

• Reporting requirements: 
  • Companies with 150+ employees will report on 2027 pay data with first submission (likely) in 2028.
  • Companies with 100–149 employees: remain on the original EU schedule, will report on 2030 pay data in 2031.
• Transparency rules (pay scales in job ads, salary history bans, right to information) are (likely – as not specifically mentioned) deferred until law goes into effect on 1 January 2027.
• The final legislation – including further clarifications or changes compared to the current draft – are expected in the course of 2026. 

This delay provides Dutch employers a short time advantage, but the overall EU deadlines remain unchanged, so preparation still needs to continue. Other Member States are still moving according to the original Directive timeline, so multinational employers must stay aligned with the wider EU schedule.

The full announcement of the Dutch government can be found here: Aankondiging (unfortunately only available in Dutch).

Please let us know should you require any further background.

Your contacts

At Deloitte, we understand that navigating the demands and complexities of pay equity and transparency can be daunting. Our proposition is designed to help you overcome this challenge and achieve your goals. Our aim is to enable you to pay employees equitably and help you demonstrate that you are doing so.

With our deep multi-disciplinary expertise in reward, employment law, technology & analytics, and behaviour change, we are well-placed to be your trusted partner on this journey. Get in touch to discuss your challenges and needs.

Kathryn Dooks, Partner, Deloitte Legal, 020 7303 2894

Deepinder Lamba, Partner, Deloitte Global Employer Services, 020 7007 2689