Median gender pay gap
Also known as mediane genderloonkloof
What does "Median gender pay gap" mean under the Pay Transparency Directive?
The difference between the median pay level of female and median pay level of male workers of an employer expressed as a percentage of the median pay level of male workers
Defined in / by
- Pay Transparency Directive (32023L0970), Article 3(1), point (e)
Last updated: 14 October 2026.
The middle woman against the middle man
The median gender pay gap compares, in effect, two people at one employer: the female worker in the middle of the women's pay distribution and the male worker in the middle of the men's. The difference is expressed as a percentage of the men's median pay level, the same base the gender pay gap uses.
Article 9(1), points (c) and (d), of the Pay Transparency Directive require a median gender pay gap for pay as a whole and a second one for complementary or variable components. Read next to the mean-based gender pay gap, the median shows where a gap sits. A mean gap well above the median gap points to a small group of very high or very low earners pulling the average. Mean and median gaps of similar size suggest the difference runs through the workforce.
Employers with 250 or more workers report the figure every year, and employers with 100 to 249 every three years (Article 9(2) to (4)).
The Dutch bill's wording
The Dutch implementing bill (Kamerstuk 36949) defines mediane loonkloof as:
het verschil tussen het mediane loonniveau van vrouwelijke en mannelijke werknemers van een werkgever, uitgedrukt als een percentage van het mediane loonniveau van de mannelijke werknemers
That follows the Directive. As at 13 October 2026 the bill is not yet law.
Questions and answers
Why does the Pay Transparency Directive ask for both a mean and a median gender pay gap?
Article 9(1) of Directive (EU) 2023/970 lists both. The two react differently to extremes: a few very high earners move the mean-based gender pay gap but barely move the median gender pay gap, so together they show whether a gap is concentrated or widespread.
Which employers report the median gender pay gap?
Employers with 100 or more workers, under Article 9 of Directive (EU) 2023/970: every year from 250 workers and every three years from 100 to 249. Under the Dutch implementing bill, employers with 150 or more workers would report first by 7 June 2028, on 2027.
Sources
- Directive (EU) 2023/970 to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanismsEUR-Lex · 17 May 2023
- Kamerstuk 36949, nr. 2: Voorstel van wet (Wet implementatie Richtlijn loontransparantie mannen en vrouwen)Officiële bekendmakingen · 20 May 2026
Glossary
Median pay level
The pay level at which half of the workers of an employer earn more and half of them earn less.
Gender pay gap
The difference in average pay levels between female and male workers of an employer expressed as a percentage of the average pay level of male workers.
Regulations
Pay Transparency Directive (Loontransparantie)
The Pay Transparency Directive, Directive (EU) 2023/970, had to be transposed by 7 June 2026. The Dutch bill (Kamerstuk 36949) targets 1 January 2027 and has employers with 150 or more workers file a first pay gap report by 7 June 2028, on 2027. As at 13 October 2026 it awaits a vote in the Tweede Kamer.
NextWet implementatie Richtlijn loontransparantie mannen en vrouwen enters into force