What Happens When Every Job Ad Shows the Pay?

Anoushka Bold
Dec 15, 2025
3 min read

Jan 2027 will arrive with a raft of new EU Dutch legal requirements related to pay fairness and transparency, requiring heavy-lifting in 2026. What's coming is a reset of how pay decisions are made, explained, and defended, and managers will be at the centre of it. With uncapped fair pay claims possible up to 5 years retrospectively, and the balance of proof sitting with the employer, let's make sure you're prepared.

What’s actually changing (in plain English)

From January 2027, pay can no longer be opaque, implied, or quietly “understood”. The rules shift pay from something organisations manage internally to something they must be able to explain internally and externally and defend objectively.

Crucially, this is about total pay, not just base salary. That means base pay plus bonus, variable pay, allowances, pension contributions and any other pay components. Here’s what that means in practice.

1. Every job ad will show the salary

No more “competitive salary”, or applicants being asked to share their expected salary level.

All job postings will need to clearly state:

the salary or salary range, and
the relevant components of total pay

This information must be shared early enough to allow fair and informed negotiation, not introduced once an offer is already close to acceptance.

For managers, this means roles need to be properly valued and benchmarked before recruitment starts, rather than resolved through last-minute negotiation.

2. Asking about salary history will be off-limits

Managers and recruiters will no longer be allowed to ask candidates what they currently earn or earned previously.

Why this matters: historic pay often reflects legacy bias, market timing or negotiation power rather than role value. The new expectation is clear, pay the role, not the person’s past.

This requires confidence in your pay frameworks, because offers can’t be justified by “that’s what they were on before”.

3. Pay decisions must be explainable and gender-neutral

Employees will be entitled to understand:

how total pay is determined,
what drives pay progression over time, and
which criteria influence differences between roles or individuals.

Those criteria must be objective and gender-neutral, typically covering:

skills,
effort,
responsibility, and
working conditions.

If a manager cannot clearly explain why two people receive different total pay for equal or equivalent work, that’s where risk begins.

4. Employees can ask for pay comparisons and expect answers

Any employee will be able to request:

their own total pay level, and
the average total pay for employees performing the same or equivalent work, broken down by gender.

This includes base pay and variable components.

Organisations will be required to respond within a defined timeframe (up to two months). This is often where informal or historic decisions surface, small differences that accumulated over time and were never revisited.

5. The burden of proof shifts to the employer

If a pay gap is challenged, the responsibility will sit with the employer to demonstrate that total pay differences are objectively justified.

Answers such as, 'historical pay progression, they negotiated well' don't cut it.

Where gaps cannot be objectively justified:

claims are uncapped, and
in the Netherlands, can reach back up to five years retrospectively.

Why this matters for managers (not just HR)

Managers sit at the centre of:

hiring decisions,
pay reviews,
promotions,
performance assessments, and
reward conversations.

That means managers will increasingly be expected to:

apply pay frameworks consistently,
explain total pay decisions clearly,
handle informed and sometimes challenging questions with confidence.

This is not about turning managers into lawyers, but it does require preparation, shared language and robust structures behind the scenes.

What smart organisations will do in 2026

The organisations that navigate this well won’t wait until January 2027. They’ll use 2026 to:

review and strengthen total pay structures
define and document objective pay criteria
identify and address unexplained gaps early
equip managers to have credible pay conversations
align recruitment, reward and performance practices

Handled well, this becomes more than compliance. It builds trust, reduces noise, and strengthens leadership credibility.

Final thought

Pay transparency doesn’t create pay problems, it reveals them.

The real question for leaders and managers is this: when someone asks “can you explain this total pay decision?”, is the answer clear, fair and defensible?

At Bold Consulting, we support organisations with the strategic analysis, operating model design and transformation work that sits behind moments like this, helping leaders make complex, high-impact changes with clarity and confidence.