From how many employees must I report on the gender pay gap?

Reporting obligation starts at one hundred employees

The reporting obligation on the pay gap applies from one hundred employees onwards. Below that threshold there is no reporting requirement, above it there is — although the frequency and start date vary depending on the salary range. The directive uses three brackets: employers with 250 employees or more report annually, employers with 150 to 249 employees report every three years, and employers with 100 to 149 employees also report every three years but start several years later than the rest.

In the Netherlands, the timing of this is different from the directive, because implementation has been delayed here. The legislative proposal that regulates the reporting obligation is currently with the Second Chamber and has not yet been adopted; the obligation therefore does not yet apply to private employers. The government aims for the law to enter into force on 1 January 2027. According to the accompanying timeline, employers with 150 or more employees will report for the first time no later than 7 June 2028, for calendar year 2027 — which means that the data for that year must be in order from the first day. Employers with 100 to 150 employees will follow only in 2031, for calendar year 2030.

Found in Article 9 and legislative proposal 36949

The size thresholds of 100, 150 and 250 employees and the associated timeline from the directive itself are set out in Article 9 of Directive (EU) 2023/970. The fact that the obligation does not yet apply in the Netherlands, and what different timeline is attached to it there, follows from legislative proposal 36949, the Act implementing the pay transparency directive for men and women: that proposal was submitted to the Second Chamber on 21 May 2026, still needs to be debated in plenary and then by the First Chamber.