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Under the Directive, all EU member states are required to implement the new rules into national law by 7 June 2026. However, the Dutch Ministry of Social Affairs and Employment has announced that this timeline is not feasible for the Netherlands. According to the Ministry, more time is needed to shape the legislation and its implementation in a way that allows employers to comply effectively while keeping administrative burdens as low as possible.
The Ministry aims to submit the draft legislation to the Council of State later this year, with parliamentary debate expected in 2026. The new target date for entry into force is no later than 1 January 2027, rather than 7 June 2026 as set out in the Directive.
Implications
The key consequence is that the measures provided for in the Directive, such as the right to pay transparency, the reversal of the burden of proof, and the ban on asking about salary history, will now be postponed until 2027 in the Netherlands.
The delay also affects the mandatory pay reporting obligations for larger Dutch employers:
- The mandatory pay reporting for employers with 150 or more employees will now apply for the first time in 2028 (covering the 2027 calendar year), instead of 2027 (covering the 2026 calendar year).
- The timing for other “reporting employers” (those with 100 to 150 employees) will be implemented in line with the Directive.
This postponement means that the Netherlands will not meet its obligation to implement the Directive on time. However, this does not mean employers can simply sit back: applicants and employees may still seek to enforce their rights under the Directive from 7 June 2026 onwards before national courts in accordance with the EU principle of direct effect.
The Dutch General Elections
The outcome of the upcoming general elections on 29 October 2025 may further delay, or possibly accelerate, the legislative process.
Takeaway for employers
Although the Netherlands has postponed implementation of the EU Pay Transparency Directive, employers should not delay compliance preparations. Reviewing and updating pay policies, job evaluation systems, and recruitment processes now will ensure smoother compliance and reduce risk once enforcement begins. Staying ahead of the curve should also position organisations to respond effectively to any potential employee claims arising after the EU’s June 2026 implementation deadline (which are still possible, despite the delay).
