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What counts as pay?

Under the pay transparency law you compare the pay of men and women, per year, per hour and per job category. But does holiday pay count? What about an IKB budget or a bonus? This video shows step by step how the law counts pay.

Last update: October 13, 2026 · Reading time: 4 minutes

This video is in Dutch.

Three pay amounts per employee

To compare fairly, the law looks at three amounts. The calculation rules come from the bill and the government's draft regulations.

Gross pay

Taxable wages, i.e. wages for payroll taxes. Subtract the holiday pay and benefits budget paid out, and add what was accrued this year.

Base pay

What remains after subtracting the complementary or variable part from gross pay.

Complementary pay

Benefits in kind and special rewards, such as a bonus. These are already part of gross pay, so you don't add them. You only identify them.

Worked example

How it works out for one employee

Whether someone has the IKB budget paid out or saves it makes no difference. Two colleagues on the same pay end up with the same gross pay.

Wages for payroll taxes€50,000
Holiday pay paid out− €3,200
Benefits budget paid out− €1,000
Holiday pay accrued+ €3,400
Benefits budget accrued+ €1,200
Gross pay= €50,400

From gross pay you identify the complementary part, what remains is base pay. Then you divide all three amounts by the paid hours from the payroll tax return, 1,800 in this example.

Per yearPer hour
Gross pay€50,400€28.00
Base pay€48,400€26.89
Complementary pay€2,000€1.11

You don't convert anything to full-time. A part-timer counts with the pay they actually earn.

Which amount do you use for what?

For each part, the law prescribes which pay amount you use.

Pay disclosure request

The employee's own pay and the average pay of men and women in the same category.

Gross pay

Mean and median pay gap

Including the distribution of men and women across the pay quartiles.

Gross pay

Gap in complementary pay

How large the gap is, and what share of men and women receive complementary pay.

Complementary pay

Pay gap per job category (part g)

Separately for base pay and complementary pay. You also share this part with all your employees.

Base payComplementary pay

Internal check per category

You compare the average gross pay of men and women, per year and per hour.

Gross pay

The 5% threshold. Does average gross pay in a category differ by five percent or more, in either direction? Then you get a signal. Not a verdict, but a reason to take a closer look.

Agency work has separate rules

A temp worker's pay is not in the hirer's payroll, because the staffing agency pays it. As a hirer you therefore report separately on your temp workers, using pay data from the agency. Do you place workers yourself? Then you need data from the hirer instead, for example to answer a temp worker's pay disclosure request.

Frequently asked questions about pay

Want to see these amounts for your own organisation?

Payqual applies the law's calculation rules to your payroll data, from pay disclosure to pay gap reporting.