does the pay transparency law also apply to temporary workers and payroll arrangements

Temporary workers and payroll employees are covered

Yes, temporary workers and payroll employees are in principle covered by pay transparency, just like employees with a standard employment contract. The directive does not make distinctions based on contract type for most provisions: it applies to workers in the broad sense, and a temporary or payroll arrangement does not change that in itself. This applies for example to the salary that must be stated in a job advertisement: if a position is filled through a temporary work agency, the question is who provides this information to the candidate, not whether the obligation applies.

Where it becomes more complicated is the question of wHO acts as the employer for this group: the temporary work agency, the client company, or both for part of it. This relates to practical questions such as who must respond to an information request from such an employee, and whether temporary workers count towards determining the size of an organisation — a question related to whether trainees and on-call workers countFor the reporting obligations, which depend on the number of employees, that difference can matter. This section cannot yet be answered with a concrete answer without distorting the text, and is therefore listed as "to be determined" — as soon as the Dutch implementation or further clarification on this provides certainty, it will be added here.

What this is based on

The directive describes its scope in terms of workers and employers without explicitly excluding temporary workers or payroll arrangements; Article 4 of Directive (EU) 2023/970 on equal work and work of equal value and Article 7 on the right to information consistently refer to "workers" in a general sense. Article 9, on reporting and thresholds, links obligations to the number of workers of an employer, but the directive itself does not clarify how temporary and payroll relationships count in that respect. This is a matter on which the Dutch implementation must provide clarity.