must I report per location or for the entire organization

Reporting is about the employer, not the location

The number of employees that counts for the reporting obligation is linked in the directive to the employer as a whole, not to a separate branch or office. Article 9 of directive (EU) 2023/970 addresses employers with a certain number of employees and makes no exception for organizations spread across multiple locations. If you have staff at multiple sites, you typically add those employees together to determine whether the threshold is met — that threshold itself comes in separate steps, as described under from how many employees must I report on the gender pay gap.

For groups with multiple legal entities, the picture is more nuanced. The directive regulates the obligation for "the employer", and what that precisely means for a group of companies with a parent and subsidiary structure is a question that will be further defined in the national implementation. This makes it one of the points where the exact scope is not yet set in stone: the bill that must transpose the directive into Dutch law is still under consideration, and precisely these kinds of practical questions — whether a subsidiary counts separately or whether it is the consolidated whole — will be worked out further there.

What Article 9 does and does not regulate

Article 9 of directive (EU) 2023/970 sets the thresholds of one hundred, one hundred and fifty, and two hundred and fifty employees and also links to it what data the report must contain, as can be read under what data must be included in a gender pay gap report. The directive itself does not work out in detail how locations, subsidiaries or international parts of a group are precisely counted — that is a choice made in the transposition into national law. Bill 36949, the Act implementing the gender pay gap transparency directive, is the document in which that Dutch interpretation will appear once it has been further considered. For the current status of that, the website of the House of Representatives is the first place to look, and for the broader context of the Dutch approach, the Ministry of Social Affairs and Employment provides background.