The implementation of the EU Pay Transparency Directive continues to evolve in the Netherlands. Although the implementation deadline of 7 June 2026 has already passed, the Dutch implementation bill is still progressing through Parliament. Based on the current parliamentary timetable, entry into force on 1 January 2027 may no longer be achievable in practice, although no new official implementation date has yet been announced.
For employers, however, the key message remains unchanged: preparation is essential.
The Directive will introduce significant obligations relating to:
- Recruitment and hiring processes
- Pay structures and job grading
- Employee communication
- Gender pay gap reporting
- Governance, data and compliance
For internationally operating organizations, there is another important dimension to consider: international employee populations, such as expatriates and highly skilled migrants. Employers will need to carefully assess which country's pay transparency obligations apply to these employees. For highly skilled migrants and expats, employers should also consider how their pay compares with that of relevant peers performing the same work or work of equal value. Identifying the appropriate comparator group is therefore key, especially in a cross-border context where remuneration packages may include mobility-related elements. Implementation timelines and national requirements may also differ across EU Member States.
At present, four European countries have already transposed the Directive into national legislation (Italy, Estonia, Slovakia, and Greece). This means that organizations with a cross-border workforce are already facing a phased and increasingly complex European compliance landscape.
The current delay in the Netherlands and other countries provides employers with additional preparation time—but it should not be seen as a reason to postpone action. Now is the time to:
- Review pay policies and processes
- Assess data quality and reporting capabilities
- Evaluate job architecture and grading
- Identify potential pay gaps
- Map international employee populations
EY supports organizations with pay transparency readiness assessments, equal pay analyses, data analytics, and practical implementation strategies to help prepare for the upcoming requirements.
Would you like to discuss what the Directive means for your organization—or specifically for your internationally mobile workforce?
Please reach out to Stijn Wichers-Diender or Ilse Jansen.
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