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Glossary termPublished inPay Transparency

Median pay level

Also known as mediaan beloningsniveau

What does "Median pay level" mean under the Pay Transparency Directive?

The pay level at which half of the workers of an employer earn more and half of them earn less

Defined in / by

Last updated: 14 October 2026.

The middle earner

The median pay level in the Pay Transparency Directive is the pay level of the worker in the middle: line up an employer's workers by pay level and half earn more, half earn less. It is the building block for the median gender pay gap in Article 3(1), point (e), which compares the median pay level of the female workers with that of the male workers.

A median moves less than an average when a few people earn far more than the rest. Take five workers earning €30,000, €32,000, €35,000, €38,000 and €200,000: the average is €67,000, the median €35,000. A pay report that shows both figures, as Article 9(1) requires for the gender pay gap, lets a reader see whether a gap comes from a few high earners or runs through the whole workforce.

Because pay level is defined as gross annual pay and the corresponding gross hourly pay, there are two possible medians, one annual and one hourly.

The Dutch bill's wording

The Dutch implementing bill (Kamerstuk 36949) defines mediaan loonniveau as:

het loonniveau waarbij de ene helft van de werknemers van een werkgever meer en de andere helft minder verdient

That matches the Directive. As at 13 October 2026 the bill is not yet law.

Questions and answers

What is the difference between median pay level and average pay level?

The median pay level is the pay level at which half of an employer's workers earn more and half earn less (Article 3(1), point (d), of Directive (EU) 2023/970). The average adds all pay levels and divides by the number of workers, so a few very high earners pull it up while the median barely moves.

Which report uses the median pay level?

The pay gap report in Article 9 of Directive (EU) 2023/970 asks for the median gender pay gap, for pay as a whole and for complementary or variable components, and both are calculated from median pay levels.

Glossary

  • Median gender pay gap

    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.

  • Pay level

    Gross annual pay and the corresponding gross hourly pay.

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.

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    Wet implementatie Richtlijn loontransparantie mannen en vrouwen enters into force