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
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.
Taxable wages, i.e. wages for payroll taxes. Subtract the holiday pay and benefits budget paid out, and add what was accrued this year.
What remains after subtracting the complementary or variable part from gross 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.
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.
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.
Mean and median pay gap
Including the distribution of men and women across the pay quartiles.
Gap in complementary pay
How large the gap is, and what share of men and women receive 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.
Internal check per category
You compare the average gross pay of men and women, per year and per hour.
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.