must I actively inform my employees about the remuneration policy

The criteria and the structure must be known, not every individual amount

The Directive is based on an information obligation: employees must be able to see on what basis their compensation and how it is structured come about. This is different from sharing a list of salaries. It is about the compensation structure — the logic behind the amounts — not a public overview of who earns what. What bill 36949 ultimately requires exactly from employers is not yet settled; the proposal is under consideration.

In practice, this means that employees must be able to check somewhere how positions are classified and what criteria determine compensation, without necessarily requiring an individual conversation or an annual notification. Making it accessible can therefore also mean: documenting it and keeping it available, so that an employee who asks for it receives an answer. What must be included in that policy is covered under what must be included in a remuneration policy, and the question of whether the works council has a role in it is described under have the compensation policy approved by the works council.

Where this follows from: Article 4 and the bill

Article 4 of Directive (EU) 2023/970 requires employers to make the criteria for the compensation structure available to employees in a way that enables an assessment of equal pay; those criteria must be objective and gender-neutral, which aligns with the question when remuneration criteria are gender-neutral. How this obligation will be translated into Dutch rules — what exactly "making available" entails and for whom — is part of bill 36949, which is still under consideration in the House of Representatives.