When must I report on the gender pay gap for the first time?

First report: 2028 for the largest employers, 2031 for the rest

Under the current draft legislation, employers with 150 employees or more will report for the first time no later than 7 June 2028, covering calendar year 2027. Employers with 100 to 150 employees will follow later: their first report is scheduled for 2031, covering calendar year 2030. This means that data on remuneration and gender must be in order from 1 January 2027 onwards, even though the report itself is not due until a year and a half later.

These dates are not yet final. The draft legislation that sets this schedule, the Law implementing the pay transparency directive, has been submitted to the House of Representatives but has not yet been debated in plenary and has not yet been presented to the Senate. The government is aiming for entry into force on 1 January 2027, but as long as both chambers have not agreed, that is a target date and not law. It is also notable that the Dutch schedule is one year later than that of the directive itself, which names 7 June 2027 as the first reporting date for employers with 150 or more employees. This difference arises because the directive's transposition deadline of 7 June 2026 has since passed without the Netherlands having completed the law.

Where this is based on: Article 9 of the directive and draft legislation 36949

The reporting dates for the European Union as a whole are set out in Article 9 of Directive (EU) 2023/970, which names 7 June 2027 as the first date for employers with 150 or more employees and 7 June 2031 for the category of 100 to 149 employees. The different Dutch dates, 2028 and 2031, come from draft legislation 36949, which is currently being considered by the House of Representatives. As long as that draft legislation has not been adopted, the reporting obligation for private employers in the Netherlands is formally not yet in force.