Pay transparency is about to become a much bigger issue for employers in the Netherlands. The change is being driven by the EU Pay Transparency Directive (EU) 2023/970 and the Dutch government's proposed legislation to implement it. The Dutch government currently intends the new rules to take effect on 1 January 2027, although the bill still needs to pass the Tweede Kamer and Eerste Kamer before that date becomes final.
Why Pay Transparency Is Becoming Important in the Netherlands
Pay transparency is closely connected to the principle of equal pay for equal or equivalent work. The issue remains relevant in the Netherlands. According to figures cited by the Dutch government, women in the business sector earned on average 14.5% less per hour than men in 2024. Some of that difference can be explained by factors such as occupation, education and management positions. Even after comparing people with similar characteristics and jobs, however, a pay difference remains.
The proposed legislation is intended to make these differences easier to identify and discuss. That means pay transparency should not be viewed simply as a recruitment trend. For Dutch HR departments, it is increasingly becoming a question of compensation structure, job evaluation, employee communication and data quality.
What Is Changing Under the Proposed Dutch Rules?
The proposed Dutch legislation would introduce several important changes. The most visible change will affect recruitment: applicants will receive information about the starting salary or salary scale for a position. The information can be included in the vacancy or provided before the discussion about employment conditions. But recruitment is only one part of the change.
Employees would also gain greater rights to information about average pay for colleagues performing equal or equivalent work. Employers would need an objective system for evaluating and classifying jobs, and larger organisations would have new gender pay-gap reporting obligations. In other words, employers cannot solve pay transparency simply by adding a salary figure to their job advertisements. The underlying compensation system also needs to make sense.
Salary Information Will Move Earlier in the Recruitment Process
One of the most practical changes for recruiters will be the timing of salary discussions. Under the proposed rules, applicants must receive information about the starting salary or salary scale for the position. This can be done through the vacancy or before the employment-conditions discussion. For a Dutch employer, this could mean changing a familiar recruitment process.
Instead of: Vacancy → Interview → Salary negotiation → Offer the process will increasingly need to be based on:
Vacancy → Salary information → Interview → Offer within the established compensation structure
That does not necessarily mean every candidate will receive exactly the same salary. Experience, education, responsibilities and other objective criteria can still influence pay. The important difference is that the employer should be able to explain why the salary offered is appropriate for the role.
Employers Will Not Be Able to Ask About Previous Salary
Another significant change is the proposed ban on asking applicants about their previous salary.
The Dutch government says the purpose is to prevent salary differences from the past from being carried into a new job. This could require changes to recruitment practices that have become routine — for example, questions about current earnings or salary expectations based on a current package.
Under the proposed framework, employers will instead need to focus on the compensation attached to the new position and the objective factors that determine where an applicant fits within the relevant salary structure. That means HR teams should review application forms, recruiter scripts and interview guidelines before the new rules take effect.
Job Evaluation Will Become More Important
This may be the less visible but more important part of the new framework. The proposed rules require employers to use a system for objective job evaluation and classification.
The Dutch government's guidance identifies factors including:
- Responsibilities
- Skills
- Effort
- Working conditions
The system must be based on objective criteria and must not disadvantage employees because of gender. Why does this matter? Imagine two positions with similar responsibilities but different titles. If one role is placed in a higher salary scale simply because of historical practice, the employer may eventually need to explain why. A structured job evaluation system gives HR a defensible way to answer that question.
The Dutch government has already published a practical guide and checklist to help employers establish a suitable job-evaluation and salary-structure system.
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What Does This Mean for Salary Scales?
Salary transparency works much better when an organisation already has a clear salary structure. For example, an employer might have:
HR Advisor — Scale 8 Senior HR Advisor — Scale 9 HR Manager — Scale 11
The exact scales will depend on the organisation and, where relevant, the applicable CAO.
The important question is whether the employer can explain why each position belongs in its particular level. That explanation could be based on:
- Scope of responsibility
- Required qualifications
- Required experience
- Decision-making authority
- Complexity of the work
- Working conditions
- Management responsibilities
This is where pay transparency moves beyond recruitment. It becomes part of the organisation's overall job architecture and compensation strategy.
Larger Employers Will Face Pay-Gap Reporting
The proposed rules also introduce reporting requirements for larger employers. Organisations with 100 or more employees will eventually have to report gender pay differences. The reporting will focus on average differences rather than publishing individual salaries.
The first reporting group is expected to be employers with 150 or more employees. If the legislation enters into force as planned, these organisations would report by 7 June 2028 on pay differences during 2027. Employers with 100 to 149 employees would follow later, with reporting expected around 2031 based on 2030 data.
This gives larger employers some preparation time, but it does not mean they should wait. Payroll and HR systems need to contain reliable data before meaningful pay-gap analysis can take place.
What Dutch Employers Should Do in 2026
The proposed law is still moving through the Dutch parliamentary process, but organisations do not need to wait before preparing.
Review Your Job Architecture
List the main roles in the organisation and check whether they have clear job descriptions, levels and responsibilities. Ask whether two jobs with similar responsibilities are being evaluated consistently.
Review Your Salary Structure
Look at how employees move through salary scales. Can HR explain why one employee is paid at the bottom of a scale while another is closer to the top? Are salary increases based on clearly defined criteria? The Dutch government specifically expects employers to be able to explain the criteria used for pay and salary increases.
Audit Your Recruitment Process
Review job vacancy templates, application forms, recruiter questions, interview scripts, salary negotiation procedures, and recruitment software. Remove questions about previous salary from the process in preparation for the proposed rules.
Review Pay Differences Before Employees Ask
Don't wait for an employee to identify a potential pay gap. Analyse compensation across comparable roles and look for differences that cannot easily be explained by objective factors. Where differences exist, document the reason. If there is no clear reason, investigate further.
Check Your HR and Payroll Data
Pay transparency will depend heavily on data. HR teams should know whether their systems can reliably connect: Employee → Job → Job level → Salary → Working hours → Gender → Other compensation. Without consistent data, pay-gap analysis becomes much more difficult.
Prepare Managers for Different Salary Conversations
Managers may need to explain compensation decisions more clearly than they do today — not simply that a salary was "agreed on," but that a role is classified at a particular level because of its responsibilities, required skills and scope, with pay determined within the corresponding salary scale. That is a meaningful cultural change for some organisations.
The Role of CAOs in Dutch Pay Transparency
For many Dutch employers, compensation cannot be discussed without considering collective labour agreements (CAOs).
A CAO may already provide salary scales, job classifications and rules for salary increases. That can actually make preparation easier because employers may already have a formal compensation framework.
However, HR teams should still check whether the existing job classifications and salary structures are consistently applied. The question is not simply whether a salary scale exists — it's whether the organisation can explain why a particular job belongs in that scale and why employees are placed at particular points within it.
Common Mistakes Employers Should Avoid
Waiting until January 2027. The proposed implementation date may be January 2027, but building job classifications, reviewing salaries and cleaning compensation data can take considerably longer.
Publishing a salary range without fixing the structure behind it. Adding a salary range to a vacancy does not solve an inconsistent compensation system. Candidates and employees may start asking why the range is what it is, and HR needs a defensible answer.
Continuing to ask about previous salary. Recruiters should begin removing salary-history questions from their processes rather than waiting until the law comes into force.
Treating pay transparency as only a recruitment issue. The changes affect recruitment, compensation, job evaluation, payroll, employee relations and reporting. It is an organisation-wide HR issue.
Ignoring smaller pay differences. A pay difference does not become relevant only when it is large. Regular analysis can help HR identify patterns early and understand where compensation practices may need attention.
What Pay Transparency Could Mean for Dutch HR
The biggest change may not be the salary information candidates see in a vacancy. It may be the pressure for employers to make their entire compensation system more explainable.
A candidate may see a salary scale before applying. An employee may later ask how their pay compares with colleagues doing equal work. A larger employer may need to report its gender pay gap. All three situations lead back to the same question: can the employer explain how it decides what people are paid?
Organisations with clear job structures, objective salary criteria and reliable HR data will be in a much stronger position. Organisations where salaries have developed mainly through individual negotiations may have more work to do.
Frequently Asked Questions
When will pay transparency rules take effect in the Netherlands? The Dutch government currently intends the implementing legislation to take effect on 1 January 2027. However, the bill still needs approval from both the Tweede Kamer and Eerste Kamer, so the date is not yet guaranteed.
Will Dutch employers have to publish salaries in every job vacancy? Under the proposed rules, applicants must receive information about the starting salary or salary scale for a position. This information can be included in the vacancy or provided before the employment-conditions discussion.
Can employers ask candidates what they earned at their previous job? The proposed Dutch legislation would prohibit employers from asking applicants about their previous salary, to prevent historical pay differences from being carried into a new role.
Conclusion
Pay transparency is becoming a significant change for employers in the Netherlands.The proposed Dutch implementation of the EU Pay Transparency Directive will affect more than job advertisements. It will influence how organisations evaluate jobs, determine salaries, communicate compensation and analyse pay differences.