Reporting obligation
Organisations with 100 or more employees must periodically report on pay differences between men and women. The report itself contains the required data per category. No action items or remediation proposals. If there is a difference of 5% or more in base pay or gross hourly pay without objective justification, a mandatory joint pay assessment (JPA) follows outside the report. Follow-up actions are therefore recommended to avoid that JPA. Payqual generates the report, flags risks internally and lets you download the result when everything is complete.
Last update: February 24, 2026 · Reading time: 7 minutes
What does the law say about reporting?
“Organisations with 100 or more employees must periodically report on the pay gap between male and female workers, per category of equivalent work.”
EU Richtlijn 2023/970, artikel 9
The Pay Transparency Directive sets strict requirements for the frequency, content and public disclosure of pay reports.
Periodic reporting
Organisations with 250+ employees report annually, organisations with 100-249 employees every three years. The first report must be submitted within the legal deadline after entry into force (Directive 2023/970, Article 9).
5% threshold and Joint Pay Assessment
If the difference in base pay or gross hourly pay between men and women in a category is 5% or more and cannot be objectively justified, a joint pay assessment (JPA) must be conducted within six months (WGBMV article 10d; Directive 2023/970, Article 10).
What exactly is a JPA?Content requirements
The report must include: the pay gap per category, the gap in supplementary or variable components, the median pay gap, the proportion of men and women receiving supplementary components, and the distribution per quartile (Directive 2023/970, Article 9(1)).
Public disclosure
Certain reporting data must be made publicly available and shared with the supervisory authority.
Sanctions for non-compliance
Member states must establish effective, proportionate and dissuasive sanctions for employers who fail to report or do not meet reporting requirements.
Sharing reporting with employees
Beyond submission, employers must share reporting information proactively, clearly and in a way that allows follow-up questions.
Actively share point g
The employer must proactively share point g of Article 10c(1) with employees and the works council: the pay gap per employee category for both base pay and supplementary or variable components. Points a-f are published by the monitoring body.
Consult the works council beforehand
Management confirms the accuracy of the report only after consulting employee representatives. The works council must have access to the methodology used to produce the figures.
Clarify on request
When requested by an employee, the works council, the Netherlands Institute for Human Rights or the Labour Inspectorate, the employer must clarify, specify and explain the pay gap within a reasonable period.
Practical implementation in your organisation
Define a fixed internal route so reporting is not only shared, but also reproducible and explainable.
- Schedule works council consultation before management formally finalises the report.
- After finalisation, distribute point g through an accessible internal channel, such as intranet or an employee portal.
- Assign a contact point for clarification requests, with a documented response timeframe and methodology.
Source
[1] Dutch bill implementing the Pay Transparency Directive, explanatory notes to Article 10c, section "Reporting method and public disclosure".
Where do things often go wrong?
Reporting is more than filling in a spreadsheet. These are the most common pitfalls.
Incomplete data
Reporting without including all compensation components (variable, bonus, pension) leads to incorrect conclusions and legal risk.
Missing deadlines
The reporting cycle is strict. Late reporting can lead to sanctions and strengthens employees' position in disputes.
No internal follow-up at >5%
The report itself is data, not an action plan. But without internal follow-up on differences >5% in base pay or gross hourly pay you walk straight into a mandatory JPA (WGBMV art. 10d; Article 10 of the directive) and strengthen employees' position in disputes.
Manual errors
Manually collecting data and performing calculations increases the chance of errors that are immediately apparent in an audit.
Why you want to avoid a mandatory JPA
The joint pay assessment (JPA) is the heaviest correction mechanism in the directive. By following up on differences >5% in base pay or gross hourly pay internally before reporting you reduce the chance you have to carry one out.
- Mandatory within six months after a report shows an unexplained difference >5% in base pay or gross hourly pay. A tight deadline alongside your regular processes.
- Carried out together with the workers' representatives; results are shared with employees and on request with the supervisory authority.
- Refusing or failing to carry out the JPA is a separate violation with sanction risk and strengthens employees' position in disputes.
The JPA is a structured, joint evaluation alongside the workers' representatives. Preventing it is cheaper than carrying it out.
Read more about the JPAHow Payqual automates reporting
Payqual collects all compensation data, performs the analysis and generates a report that meets all PTD requirements. Risks are flagged so you can act before the report is finalised.
Connect data
Connect your HR and payroll system to Payqual. All compensation components are automatically loaded and categorised.
Analysis and internal risk signalling
Payqual analyses pay differences per cluster and flags (alongside the report) where base pay or gross hourly pay differs by 5% or more. You immediately see which categories need attention so you can correct or objectively justify before submission. This signalling sits outside the formal report.
Download report
Once all risks have been assessed and corrected where needed, download the complete report. Ready for the regulator.
Payqual monitors continuously. You don't have to wait until the deadline approaches; risks are flagged immediately when new data becomes available.
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847
Employees
10
Clusters analysed
94%
Compliance score
Q1 2026
Report date
Always up-to-date
Reports are automatically updated when new data becomes available.
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Complete audit trail of all analyses, changes and approvals.
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