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Company-size guide: reporting tiers
Transparency and equal-pay basics apply to employers of any size. Gender pay-gap reporting duties phase in by headcount, starting at 100 employees. Here's the shape of it.
Review Snapshot as of September 2026. Under the Directive as originally written, reporting starts with the largest employers (250+) and phases down; the Dutch bill currently before parliament groups 150+ together with first reporting for calendar year 2027 (due by June 2028) — a year later than the EU schedule. Confirm against the enacted text once it passes.
| Tier | Headcount | What generally applies | Roughly when |
|---|---|---|---|
| Small | Under 100 | Vacancy pay-range transparency, no salary-history questions, employee pay-information requests. | Applies from transposition — no gap-reporting duty |
| Medium | 100–149 | All of the above. Gender pay-gap reporting for this band is not yet scheduled in the Dutch bill. | Review Not yet dated — the Directive itself gives this tier until 2031 |
| Large | 150–249 | All of the above, plus gender pay-gap reporting — grouped with the 250+ tier under the current Dutch bill. | First report: calendar year 2027, due by June 2028 Review |
| Largest | 250+ | All of the above, plus annual gender pay-gap reporting — first tier in scope under the Directive. | First report: calendar year 2027, due by June 2028 Review |
Note: the Directive's original schedule puts the 150–249 band on a three-yearly reporting cycle and the 100–149 band on one starting only in 2031. The Dutch bill before parliament currently proposes grouping 150+ together on an earlier timeline instead — confirm which version is enacted before advising a specific employer.
This table is a simplified summary for orientation, not a compliance checklist. A Rapid Pay Transparency Assessment will tell you exactly what applies to your organisation and when.