The Dutch bill is still pending, but its real pressure begins with roles, ranges and reasons.
A founder is preparing a vacancy for a senior employee. The candidate will be difficult to find, the budget is tight, and a recruiter wants an answer today. The familiar question is what the company can afford.
A second question is moving closer. Why does this role carry this salary, and would that reason hold beside the pay of existing staff doing equivalent work?
That question sits behind the Dutch bill implementing EU Directive 2023/970 on pay transparency. The official legislative calendar recorded a parliamentary response on 2 September 2026. As of 4 September, the bill remains before the Tweede Kamer.
The government intends the rules to apply from 1 January 2027, subject to parliamentary approval.
The proposal would require applicants to receive the starting pay or pay range before salary negotiations. Employers and intermediaries would no longer ask about current or previous salary.
Employees could request information about their own pay and gender-split average pay for colleagues doing equal or equivalent work.
The threshold can mislead
Periodic reporting would begin at 100 employees. That visible threshold may tempt a small employer to treat pay transparency as a large-company issue. Its practical reach is wider.
Recruitment, job classification, and employee information rights would reach much further if Parliament passes the bill. Employers of every size would need an objective, gender-neutral structure for valuing and classifying jobs.
A company with twelve employees may never produce a statutory pay-gap report. It may still face the harder question: why does one project manager earn more than another?
A sound answer may involve experience, responsibility, scarce skills, or measurable performance. The point is not to make every salary identical. It is to know which differences have a consistent business reason.
Equal pay is not a new Dutch principle awaiting this bill. Current law already prohibits sex discrimination in recruitment and employment conditions. It covers equal pay for work of equal or approximately equal value.
Where facts create a presumption of discrimination, the employer may have to show that the law was respected.
Payroll records amounts, not reasons
Most small-company salary problems do not begin with bad intent. They begin with urgency. A candidate has another offer. A valued employee threatens to leave. A founder rewards someone who carried the business through a difficult year.
The decision may be entirely defensible, yet its reasoning remains in a conversation or message thread. Months later, payroll shows the higher amount. It does not carry the commercial pressure, added responsibility, or approval behind it.
A payroll export can reveal a difference. The explanation lies in the connection between the actual work, job category, pay range, and recorded exception.
The government plans to use existing payroll administration and wage-tax return data as far as possible for future reporting. That may reduce duplicate work. It will not repair outdated job descriptions or informal salary arrangements.
Software can calculate. It cannot decide whether two grand titles conceal essentially the same work.
National figures need a local answer
CBS reported that women’s average hourly wages were about 10 percent lower than men’s in 2025. On a median basis, the difference was about 5 percent.
Those figures describe the Dutch labour market. For an employer, the useful comparison is closer to home. What work is actually being performed? Which responsibilities differ? How were bonuses, allowances, overtime, and recurring benefits treated?
Who approved the salary, and was the same reasoning available to other employees in comparable circumstances?
This is where compliance meets cash. An inherited pay exception can affect future rises, pension costs, and the price of retaining other staff. If several roles need adjustment, the wage bill may change faster than customer contracts allow.
A founder cannot manage that pressure from a headline percentage. The figures must connect to margins, pricing, and the real staffing plan.
A quiet review before the question arrives
The founder with the vacancy need not wait for the final law to improve the decision. Before agreeing on a number, the business can compare the vacancy with work already performed inside the company.
It can define a range, record the objective reason for an exception, and make sure payroll coding matches the agreement. The same calm review can cover recent hires, promotions, and retention increases.
Informal exceptions should not automatically be treated as wrong. They should be understood. Someone also needs to own the link between job descriptions, salary decisions, and payroll, even when recruitment, contracts, and administration sit with different people.
Pay information is sensitive, especially in a small team where an average may reveal more than intended. Access and handling matter. So does restraint.
The aim is not open discussion of individual salaries. It is a fair process that can answer a proper question without exposing information carelessly.
The final rules and technical details still require parliamentary completion. The practical direction is already visible. Pay transparency starts long before a report is produced.
It starts when a role is described, a salary is offered, and someone records why the decision made sense.
If you want to review how your roles, salary ranges and payroll records fit together, contact me for a practical assessment.
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- Wetsvoorstel loontransparantie: verbod vragen naar salaris, recht op informatie, loonrapportage · Salaris Vanmorgen
- Overheid.nl Wetgevingskalender - Legislative status and expected commencement
- Rijksoverheid - Who would face which transparency duties
- Rijksoverheid - Reporting timetable and use of payroll data
- Rijksoverheid - Job valuation and classification
- Wettenbank - Existing equal-pay law
- CBS - Latest official picture of the gender pay difference
- CBS - Recent acceleration in the measured pay-gap decline
