The Dutch government has announced that the target date for introducing domestic legislation to implement the Pay Transparency Directive is now 1 January 2027, instead of 7 June 2026 as required under the Directive.
The Netherlands was one of the first member states to publish draft implementing legislation – see our previous blog here. It says it is working on a careful implementation of the Pay Transparency Directive, but that the original planned timeline for timely implementation of the Directive has proven unfeasible – possibly not helped by the collapse of the Dutch government on 3 June. One of the main reasons given for the change is that the government says it needs more time to design the national legislation and its implementation in such a way that employers can meet their obligations effectively while keeping the administrative burden to a minimum. That said, based on what we have seen of the Directive so far, achieving a truly “minimal administrative burden” may be an overly optimistic goal.
The government aims to submit the draft bill to the Council of State before the end of this year, with parliamentary debate expected in 2026.
This delay will create a transitional period during which the Directive is already legally binding at EU level, but has not yet been fully incorporated into Dutch national law. During this interim phase, the Dutch courts will interpret existing national laws in line with the Directive’s objectives, a principle known as...
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