The Pay Transparency Directive: what you can do now to close the pay gap

The short answer: yes.

The pay gap indicates the difference in how much men and women earn on average per hour (gross).

In the Netherlands, the pay difference between men and women averages 13%. This was last calculated in 2022 by CBS, placing the country slightly above the average European pay gap of 12.7%. By comparison, in Belgium – one of the leaders in equal pay – the average pay gap is 5% (source: Euronews).

Women therefore earn an average of 13% less per hour than men, but there are large differences between sectors: in 2022, the average hourly wage for women in the public sector was 5.1% lower, while in the private sector the pay gap was 16.4%.

The pay gap is partly explained by the fact that women more often work in lower-paying sectors and less often hold top positions (with top salaries).

The figures above therefore refer to the unadjusted pay differences between men and women.

CBS also calculates the adjusted pay gap: adjusting for factors such as job level, age and experience.

But even after adjustment, an unexplainable pay gap remains.

The adjusted pay gap in the Netherlands is approximately 2 to 3% according to research by AWVN.

So in most jobs in the Netherlands, there is still no equal pay for equal work.

📊 At the top of the private sector, the differences are greatest: the pay gap between the highest-earning men and women is 9.0% (adjusted).

One of the main reasons for the gender pay gap is that most employers still provide no transparency about pay differences in their organisation.

That is why the EU has adopted a directive to ensure more salary transparency, a first step to close the pay gap.

The directive must be transposed into Dutch law by 7 June 2026. The law is expected to take effect on 1 January 2027.

The key change? The responsibility for demonstrating equal pay shifts to the employer, rather than the employee.

• Every employer must provide transparency about their compensation policy.
• Compensation criteria must be gender-neutral – based on performance, skills development and seniority.
• Employers may no longer ask about a candidate's previous salary.

The EU Pay Transparency Directive applies from June 2026 to all employers: organizations of all sizes and in all sectors, public and private.

• Employers with 100 or more employees must also regularly publish a report on the gender pay gap in their organization.
• If the report shows that your organization has a pay gap of at least 5% that is not explainable (based on objective and gender-neutral criteria), then as an employer you must draw up an action plan to address the gap.

You can read more about this on the AWVN website.

That is not yet 100% clear: the Dutch Ministry of Social Affairs is currently drafting the concept texts for the new law.

What is clear: if you do not comply with the directive, it can have major administrative and financial consequences.

• Employees can take legal action against their employer
• Employees who have suffered damage because there was no equal pay are entitled to full compensation for the lost wages
• Fines or sanctions may apply to organizations that do not pay equally (source: AWVN)

Fortunately, you can already take steps to establish a fair reward policy based on objective criteria – and even reduce the national wage gap. 👇

"Everyone has the right to equal pay for equal work." That is a fundamental principle from the Universal Declaration of Human Rights (article 23 to be precise).

Moreover, wage discrimination is prohibited by law in the Netherlands. An employer may not, under the Civil Code, differentiate between men and women in terms of employment conditions – which includes salary.

Yet the gender pay gap still exists, in the Netherlands and throughout Europe.

The income inequality between men and women indicates a larger societal problem, for which there are various causes (and therefore many different solutions).

The causes according to experts:

1. The main cause is the unequal distribution of care tasks in our society: women more often bear the responsibility for childcare
2. Because they bear more responsibility for care tasks, women more often work part-time. And because working full-time is still the norm for many management positions, this limits their career advancement opportunities
3. Professions in which many women work, such as healthcare and education, pay less well
4. The glass ceiling: women are much less often appointed to higher positions
5. And there can be discrimination based on gender

Now for the positive side: it has many advantages if your organization takes concrete steps to reward more fairly and close the gender pay gap.

Are you curious about how far your organization has come with pay transparency? Download the free Pay Transparency Act Checklist and discover your next step!

Whether you want to comply with the new law or get ahead of it, you can start preparing now.

Make sure you provide transparency about salaries in your organisation, and that pay is based on objective criteria!

In practice, a pay gap mainly reflects the distribution of men and women across job levels.

The more women in lower-paid positions, the larger the (unadjusted) pay differences.

So encourage a fair gender distribution across all job groups – including management level. Actively encourage women to apply for internal vacancies.

Do this by including objectively measurable criteria in your job framework, such as required skills, or concrete goals and KPIs.

Then evaluate employees based on those objective criteria in a fair evaluation process:

• Actual performance: achieving goals and KPIs
• The development shown in their skills
• Behaviour aligned with your core values

This prevents bias from creeping into evaluations and compensation decisions.

Also apply the objective compensation criteria to your job evaluation system or pay structure.

Check whether your current pay structure is still correct. Are you scaling jobs and salaries based on gender-neutral criteria?

Standardise salary increases:

• Set a fixed percentage raise for employees who exceed expectations
• This prevents salary increases from differing between men and women

For a transparent compensation policy, you also need correct, up-to-date data about compensation in your organisation.

Make sure you can track salary data in a secure, user-friendly HR tool.

Be transparent about salary levels and salary scales – for all positions and job levels in your organization.

And do so right from the application process:

• Set a fair starting salary. Look at the team and job level a new colleague will join, and align the salary accordingly.
• For existing positions, you can share salary scales via job profiles, your HR system, or Performance Management tool

💡 Tip: do not ask for the last earned salary in the application procedure, that is no longer allowed. Even better: already share a salary range in the vacancy: this can yield you up to 45% more applicants according to research by Indeed

Everyone has unconscious biases – that is completely human.

It already helps a lot to be aware of the biases that can creep into your evaluation process, job classification or pay structure.

• Check whether male and female managers evaluate skills consistently, and calibrate review results
• Do you use a fixed structure for evaluation conversations?
• Does every employee get an equal opportunity to negotiate salary?

Make sure managers and leaders are informed. Everyone involved in employee evaluations and hiring must be aware of the salary scales.

It can also be beneficial to organise training on unconscious biases to create more awareness among managers.

The most important thing? Establish objective criteria for evaluating performance, development and promotions, and incorporate these into your compensation policy.

Keep critically reviewing your pay structure, even if you have fewer than 100 employees.

Start tracking and reporting, so you can regularly evaluate whether your policy is being followed and whether salaries in your organisation are still gender-neutral.

A good time to analyse salary increases and average pay differences is after each evaluation round in your HR cycle.