Do I need to send all parts of the report to employees?
No. Only point g (the pay gap per category for base pay and variable components) needs to be shared by you. Points a through f are published by the monitoring body.
HomeSharing reporting with employees
The three obligations under Article 10c Wgbmv
Sharing reporting with employees
Submitting the report to the monitoring body is step one. Step two — which many employers overlook — is that you must actively provide point g to your own employees and works council. And when someone asks a follow-up question, you must be able to answer it properly.
Last update: March 7, 2026 · Reading time: 7 minutes
Quick answer
- Point g (pay gap per category, base pay and variable components) must be shared by you directly with employees and the works council.
- Management only confirms the report after consulting employee representatives.
- On request from an employee, works council, NIHR or Labour Inspectorate, you must clarify within a reasonable period.
“The employer provides the information referred to in paragraph 1, point g, to the employees and the works council.”
Dutch bill implementing the Pay Transparency Directive, Article 10c
What does Article 10c of the draft law say?
Three separate obligations apply in addition to filing the actual report.
Actively share point g
The pay gap broken down by employee category — for both base pay and supplementary or variable components — must be shared by you. Points a through f are published by the monitoring body; you do not need to distribute those separately.
Consult the works council beforehand
Before management confirms the accuracy of the report, employee representatives must have been consulted. The works council must also have access to the methodology used to produce the figures.
Clarify on request
Employees, the works council, the Netherlands Institute for Human Rights and the Labour Inspectorate can request clarification. You must then provide a substantiated, specific response within a reasonable time.
What is included in point g?
This point specifically covers pay differences broken down per employee category.
Point g only — employer responsibility
Base pay
The pay gap in fixed base salary per category of workers performing equal or equivalent work.
Supplementary or variable components
The pay gap in bonuses, commissions, allowances and other variable components, also broken down per category.
Points a through f are published by the monitoring body.
Both components must be made transparent separately per category. A single combined average is insufficient.
Practical internal process
Define a fixed sequence so that reporting is reproducible and demonstrably shared.
1
Consult the works council
Schedule the works council consultation before finalisation. Give the works council access to the methodology used, not just the outcome.
2
Distribute point g
After finalisation, share point g via an accessible internal channel: intranet, employee portal or HR system.
3
Designate a contact point
Assign a contact person for clarification requests. Document the response timeframe and methodology so you can answer questions reproducibly.
Who can request clarification?
Four parties have the explicit right to have the report clarified. Each request requires a substantiated response within a reasonable period.
Employee
Any individual employee can request clarification of their position relative to the reported category averages.
Works council
The works council can structurally request clarification as part of its advisory and approval rights on pay policy.
Netherlands Institute for Human Rights
The NIHR can, as supervisory authority, demand clarification where it suspects structural unequal pay.
Dutch Labour Inspectorate
The Labour Inspectorate can, in the context of enforcement, request a full clarification with substantiation of the methodology used.
Document the methodology in writing. Being able to reproducibly demonstrate how the figures were produced is the core of the clarification requirement.
How Payqual supports this
Payqual does not just generate the report — it also helps you set up the internal distribution process.
Point g ready for distribution
Payqual generates point g as a separate export file, ready to share via intranet or portal.
Methodology documentation
The full calculation method including categorisation is recorded and immediately available for the works council and regulators.
Audit trail for clarification requests
Every request and response is logged so you can demonstrate during an inspection what was shared and answered, and when.
Sources
- [1]Dutch bill implementing the Pay Transparency Directive, explanatory notes to Article 10c, section "Reporting method and public disclosure".
Frequently asked questions
What if an employee wants to understand the report but I haven't documented the methodology?
Then you face a serious risk. The law requires you to provide substantiated clarification on request. If you cannot reproduce the methodology, you cannot meet that obligation. Always document the method in writing.
Related articles
Ready to set up the distribution process?
Payqual helps you prepare point g for distribution, document the works council consultation and handle clarification requests traceably.