From the perspective of legal compliance, when should companies issue the first annual notice to employees? Should it be sent immediately after the local transposition law enters into force, for example in June if the national legislation is then in force, or can it be sent later in 2026 and, if so, what is the earliest justifiable deadline in relation to the date the national legislation enters into force?

This refers to the obligation to inform employees annually of their right to request information on individual or average pay levels, as well as the ways in which they can exercise that right. The Directive does not answer this question and does not set a deadline by which this annual obligation must be fulfilled. The Draft Act amending and supplementing the Protection against Discrimination Act provides for ‘by 31 January of each calendar year’.