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Glossary termPublished inPay Transparency

Workers’ representatives

Also known as werknemersvertegenwoordigers

What does "Workers’ representatives" mean under the Pay Transparency Directive?

The workers’ representatives in accordance with national law and/or practice.

Defined in / by

Last updated: 14 October 2026.

Who represents the workforce, and what they do here

The Pay Transparency Directive does not say who workers' representatives are; it takes them from national law and practice. Recital 24 mentions trade unions or other workers' representatives, and says that where there are none, workers should be able to be represented by a representative of their choice.

Their role runs through the pay transparency duties. The objective, gender-neutral criteria behind pay structures are agreed with them where they exist (Article 4(4)). Workers may request pay information through them (Article 7(2)). The employer's management confirms the accuracy of the pay gap report after consulting them (Article 9(6)). A joint pay assessment is carried out in cooperation with them (Article 10(1)), and recital 43 says that where there are none, workers designate them for the assessment. They may also act on behalf of or in support of a worker in proceedings (Article 15).

In the Netherlands

The Dutch implementing bill (Kamerstuk 36949) works mainly through the works council (ondernemingsraad). It requires the employer to consult the works council on the accuracy of the pay gap information (new Article 31d(1) of the Wet op de ondernemingsraden) and gives the works council a consent right over the job evaluation system and its gender-neutral criteria, the division into categories of workers, the remedying of unjustified differences and the joint pay assessment (Article 27(1)(c)). Schools, universities and universities of applied sciences get parallel rights for their participation councils. As at 13 October 2026 the bill is not yet law.

Questions and answers

Who are workers' representatives under the Pay Transparency Directive?

Whoever national law and practice says they are: Article 3(1), point (m), of Directive (EU) 2023/970 defines them by reference to national law and/or practice. Recital 24 mentions trade unions or other workers' representatives. In the Netherlands the implementing bill works mainly through the works council.

What must the works council approve under the Dutch pay transparency bill?

Under the bill's new Article 27(1)(c) of the Wet op de ondernemingsraden, the works council's consent covers the pay or job evaluation system, its gender-neutral criteria, the division into categories of workers, how unjustified differences are remedied and the joint pay assessment, including the plan to remedy differences. The bill was not yet law as at 13 October 2026.

Glossary

  • Labour inspectorate

    The body or bodies responsible, in accordance with national law and/or practice, for control and inspection functions in the labour market, save that, where provided for in national law, the social partners may carry out those functions.

  • Category of workers

    Workers performing the same work or work of equal value grouped in a non-arbitrary manner based on the non-discriminatory and objective gender-neutral criteria referred to in Article 4(4), by the workers’ employer and, where applicable, in cooperation with the workers’ representatives in accordance with national law and/or practice.

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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