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Glossary termPublished inPay Transparency

Pay

Also known as beloning

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

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

Defined in / by

Last updated: 14 October 2026.

Basic pay plus everything else the employer gives

Pay under the Pay Transparency Directive has two parts: the ordinary basic or minimum wage or salary, and the complementary or variable components on top of it. Recital 21 lists examples of the second part: bonuses, overtime compensation, travel facilities, housing and food allowances, compensation for attending training, payments in the case of dismissal, statutory sick pay, statutory required compensation and occupational pensions. The list is open. The recital says such components may include those items "but are not limited to" them.

The split matters for the pay gap report. Article 9(1) asks for the gender pay gap and the median gender pay gap twice, once for pay as a whole and once for complementary or variable components only, and for the share of women and men who receive such components at all. A benefit an employer leaves out of pay changes several of those figures at once.

The Dutch bill's wording

The Dutch implementing bill (Kamerstuk 36949) puts the definition into Article 1 of the Wet gelijke behandeling van mannen en vrouwen as loon:

de vergoeding door de werkgever aan de werknemer verschuldigd voor diens arbeid, zijnde het basisloon en de aanvullende of variabele componenten

The bill's text does not repeat the Directive's "in cash or in kind" or "directly or indirectly", and it lets an order in council define basisloon and brutoloon further (new Article 1(3)). As at 13 October 2026 the bill is not yet law.

Questions and answers

Do pension contributions count as pay under the Pay Transparency Directive?

Recital 21 of Directive (EU) 2023/970 names occupational pensions among the complementary or variable components of pay, alongside bonuses, overtime compensation and statutory sick pay. The definition in Article 3(1), point (a), covers any consideration a worker receives directly or indirectly from the employer in respect of employment.

Is pay the same as loon in the Dutch implementing bill?

The Dutch bill (Kamerstuk 36949) defines loon as the payment the employer owes the worker for their work, being the basic wage and the complementary or variable components. That follows the Directive's two-part split and leaves further detail to an order in council. The bill was not yet law as at 13 October 2026.

Glossary

  • 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 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