What must be included in a remuneration policy?

Four objective criteria form the basis

A remuneration policy establishes how jobs within an organisation are weighted and remunerated, based on criteria that have nothing to do with sex: the skills a job requires, the effort needed for it, the responsibility that comes with it and the circumstances in which the work is performed. These are the four building blocks of the remuneration structure from the directive. A remuneration policy translates those building blocks to the organisation itself: which jobs are considered equivalent, how salary scales relate to that classification, and which allowances or secondary conditions apply to which category.

Additionally, a remuneration policy should include information on how the organisation handles the other obligations from the directive: how a job applicant learns the starting remuneration or range in advance, and how a request from an employee to find out the average remuneration level of his or her category is handled. For Dutch employers, this is currently in a transition phase: the Act implementing the pay transparency directive has not yet been adopted by the Second Chamber and does not yet apply to private employers. Those who want to be ready by the target date of 1 January 2027 are well advised to set up the job classification and remuneration policy this autumn — a classification based on objective criteria does not happen overnight.

The legal basis: Article 4 and bill 36949

The four criteria for a gender-neutral remuneration structure are set out in Article 4(4) of Directive (EU) 2023/970. The Dutch transposition of the directive, with the corresponding deadlines and thresholds for reporting, is set out in bill 36949, which was submitted to the Second Chamber on 21 May 2026 and on which votes must still be held in both Chambers.