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Glossary termPublished inPay Transparency

Pay level

Also known as beloningsniveau

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

Gross annual pay and the corresponding gross hourly pay

Defined in / by

Last updated: 14 October 2026.

Two figures, not one

Pay level in the Pay Transparency Directive is a pair of figures: gross annual pay and the gross hourly pay that corresponds to it. Recital 22 gives the reason, a uniform presentation of the information the Directive requires, and allows the calculation to start from the pay actually set for the worker, whether that is set annually, monthly, hourly or otherwise.

Every other pay measure in Article 3 builds on this one. The gender pay gap compares average pay levels, the median gender pay gap compares median pay levels, and quartile pay bands rank workers by pay level. The right to information in Article 7(1) gives a worker their individual pay level and the average pay levels, broken down by sex, for categories of workers doing the same work or work of equal value.

The hourly figure takes hours worked out of the comparison. A worker on 24 hours a week earns less per year than a colleague on 40 hours at the same rate, while per hour the two are paid the same. The annual figure alone would show a difference that the hourly figure does not.

The Dutch bill's wording

The Dutch implementing bill (Kamerstuk 36949) defines loonniveau more briefly:

het brutoloon

It does not mention the annual and hourly split, and it allows an order in council to define brutoloon further (new Article 1(3) of the Wet gelijke behandeling van mannen en vrouwen). As at 13 October 2026 the bill is not yet law.

Questions and answers

Is pay level under the Pay Transparency Directive annual or hourly?

Both. Article 3(1), point (b), of Directive (EU) 2023/970 defines pay level as gross annual pay and the corresponding gross hourly pay, and recital 22 says pay levels should be expressed in both forms so that the information is presented uniformly.

Is pay level gross or net?

Gross. Article 3(1), point (b), of Directive (EU) 2023/970 names gross annual pay and gross hourly pay, and the Dutch implementing bill defines loonniveau as het brutoloon, the gross wage.

Glossary

  • Quartile pay band

    Each of four equal groups of workers into which they are divided according to their pay levels, from the lowest to the highest.

  • 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.

  • Pay

    The ordinary basic or minimum wage or salary and any other consideration, whether in cash or in kind, which a worker receives directly or indirectly (complementary or variable components) in respect of his or her employment from his or her employer.

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