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Dutch pay transparency law set to miss 1 January 2027

The government still aims for 1 January 2027, but the Tweede Kamer has not debated bill 36949 and the Eerste Kamer still has to follow. Employers should not plan on that date, and should not wait for it either: the EU deadline passed on 7 June 2026.

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Will the Dutch pay transparency law take effect on 1 January 2027?

Unlikely. The government still writes that it "streeft ernaar het wetsvoorstel per 1 januari 2027 in werking te kunnen laten treden" (nota naar aanleiding van het verslag, Kamerstuk 36949, nr. 6, 2 September 2026). But the Tweede Kamer has not yet debated bill 36949, and the Eerste Kamer has to treat it after that. The Act takes effect on a date set by royal decree.

The Tweede Kamer website lists the plenary debate on 7 December 2026 and on 11 January 2027. A third entry on the same page gives 14 October 2026. Two advisers, Dirkzwager and OR Academy, now work from a later start; OR Academy expects 1 July 2027.

The EU deadline for the Pay Transparency Directive was 7 June 2026. It has passed.

Where the bill stands

Each label gives the date as the source states it and who set it.

2026

  1. 21 May 2026 · Set by the government

    Bill 36949 submitted to the Tweede Kamer

  2. 7 June 2026 · Set by law

    Transposition deadline of Directive (EU) 2023/970 passes (Art. 34)

  3. 2 September 2026 · Set by the government

    Government reply still aims for 1 January 2027

  4. 9 September 2026 · Set by the Tweede Kamer

    Bill put on the list for a plenary debate

  5. 7 December 2026 · Indicative: Tweede Kamer website

    Plenary debate, one of the dates the Tweede Kamer website lists

2027

  1. 1 January 2027 · Target: government, 2 September 2026

    Target date for entry into force

  2. 7 June 2027 · Set by law

    First pay gap reports due under the Directive for employers with 150 or more workers (Art. 9)

The reporting date is a second gap

The Dutch bill moves the first pay gap report for employers with 150 or more workers to 7 June 2028, over calendar year 2027. The Directive sets 7 June 2027.

The Raad van State objected in its advice: "De richtlijn biedt geen ruimte om uit te gaan van een latere datum." The government did not follow the advice on that point. Whether the Commission accepts that is a question for later, and so far we have found no formal notice from Brussels.

What employers can prepare now

The Directive's duties for recruitment and for employees' questions are the same whichever date the Dutch Act carries, and none of them depends on a reporting system.

Candidates must get information on the starting pay or its range before the interview (Article 5(1)). Employers may not ask about pay history (Article 5(2)). Employees get a right to request their own pay level and the average levels, by sex, for workers doing the same work or work of equal value (Article 7(1)).

Get the job structure right first. A comparison of work of equal value needs objective, gender-neutral criteria (Article 4(4)), and that is the part that takes months.

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