Netherlands delays implementation of the Gender Pay Transparency Directive (update)

21 January 2026 1 min read

By Thomas Boot, Johan Zwemmer and Rima Tahmasian

At a glance

The Dutch government has just confirmed that it will postpone the implementation of the EU Gender Pay Transparency Directive (Directive), which was scheduled for 7 June 2026.
Despite the Netherlands being one of just a few Member States to have published draft legislation (in March 2025), the stepping down of the government on 3 June 2025 has had an impact on the progress of proposed new legislation, including the implementation of the Directive.
The Netherlands now plans to bring its implementing provisions into force on 1 January 2027, over six months past the 7 June 2026 deadline set under the Directive.
In addition, the Netherlands' legislation will modify some of the Directive obligations for reporting gender pay gaps. The government has indicated that employers with 150 or more employees will now be required to publish their first gender pay gap report based on the gender pay data from the calendar year 2027 (instead of the calendar year 2026). It is not yet clear what impact this has on the timeframe for publishing the first gender pay gap reports. Further government updates may clarify this.
The requirements relating to employers with 100 – 149 workers remain unchanged.

Update: 21 January 2026

In light of the European Commission's response to European Parliamentary questions about Netherlands' proposed delayed implementation of the Gender Pay Transparency Directive, the Dutch government may now reconsider its position. The European Commission said:

'It expects all Member States to implement the directive by the deadline of June 2026.

The Commission recalls that Member States must transpose the directive within the legal deadline. Should a Member State fail to notify its transposition measures on time, the Commission may launch infringement proceedings, starting with a letter of formal notice in accordance with Article 258 of the Treaty on the Functioning of the European Union'.

The Dutch government must now decide next steps.

For more information on the Dutch legislation, see our earlier News item: Draft bill published for implementation of the EU Gender Pay Transparency Directive (update) - DLA Piper GENIE