Recently, the Cabinet has postponed several tax and labor law regulations. These include the Lump Sum Law, the mandatory CO₂ mileage registration and the Wage Transparency Law. The postponement gives employers more time to prepare for the new rules, but at the same time creates uncertainty about the eventual implementation. Is postponement only temporary, or is postponement still imminent?
Postponement of the Lump Sum Law
The Lump Sum Law regulates that employees can withdraw up to 10% of their accrued pension assets in a lump sum on their retirement date.
Whereas the law was initially (or rather, after several previous moments of postponement) supposed to come into force on July 1, 2026, the Spring 2026 Memorandum reveals that this date is no longer feasible. Implementation of this law has been postponed and is not expected to take effect until January 1, 2029. A delay of no less than 2.5 years. And that while the regulation was originally intended to see the light of day on Jan. 1, 2022.
Expanding the number of persons for CO₂ registration
Since July 1, 2024, employers with 100 or more employees are required to record and report CO₂ emissions from employee commuting and business mobility.
A number of things are important for this registration. For example, it should be recorded how many kilometers the employee travels to work. In addition, employers must also record the type of vehicle (and, if applicable, the type of fuel) the employee used to travel his or her business mileage and commute.
A decree published by the Secretary of State modifies the obligation to record mileage under the CO₂ reporting work-related personal mobility. The obligation will still apply to employers with 250 or more employees, with this change taking effect retroactively as of Jan. 1, 2026. This will spare SMEs, thus reducing the regulatory burden. A final implementation date is not yet known. Until the official announcement, SME employers would be wise to continue collecting relevant data.
Wage Transparency Act
With the Wage Transparency Act, the government wants to force more openness about remuneration and salary structures within organizations. The law is a result of a European directive. By obliging employers to be more transparent about pay criteria, job evaluation and salary scales, the government wants to make unjustified pay differences transparent. The ultimate goal of the law is to reduce the gender pay gap.
The introduction of this law has been delayed. Although EU member states must transpose the underlying directive into national law by June 7, 2026, the Netherlands will not meet this deadline. The intended effective date has therefore been postponed to January 1, 2027, giving both legislators and employers more time for careful implementation.
In conclusion
If you have any questions after reading the above, please feel free to contact your Govers contact person or the Payroll Tax Focus Group at loonheffingen@govers.nl or by phone at 040 2504 504.