Poland is preparing for significant changes to its employment landscape as the EU Pay Transparency Directive approaches implementation. While Poland currently lacks specific pay transparency legislation, the upcoming directive will introduce comprehensive requirements to disclose salary information, analyze pay gaps, and ensure equal pay for work of equal value.
With the implementation deadline of June 2026 approaching, employers in Poland need to understand what’s coming and how to prepare their organizations for this new era of wage transparency.
This article serves as a comprehensive guide to help employers navigate the upcoming changes and prepare effectively for the new pay transparency landscape in Poland.
Current Pay Transparency Landscape in Poland
Currently, Poland does not have specific legislation mandating pay transparency or gender pay gap reporting requirements. The Polish Labor Code (Kodeks pracy) does not include provisions regulating the disclosure of salary information, leaving this largely to employer discretion.
Without explicit regulations, many Polish employers have traditionally maintained confidentiality around compensation matters. However, this approach will need to change significantly as Poland implements the EU Pay Transparency Directive. To better understand how pay transparency can impact your workforce, consider the broader effects it has on employee satisfaction.
Equal Pay in the Current Legal Framework
While specific pay transparency requirements are absent, Poland does have broader equal pay protections under its labor laws. The country has overarching legislation that prohibits gender-based pay discrimination, alongside some field-specific regulations in sectors like banking.
In 2018, the Polish government made an initial step toward promoting pay equity by developing a software application to help employers estimate their adjusted gender pay gap. This tool was designed to help companies develop non-discriminatory pay structures by accounting for factors like education and experience.
Beyond legal compliance, pay equity plays a crucial role in shaping employee engagement and retention. Learn more about that here.
The Upcoming 2026 EU Pay Transparency Directive (Dyrektywa o przejrzystości wynagrodzeń)
The EU Pay Transparency Directive 2023/970, adopted on May 10, 2024, will introduce new obligations for employers in Poland regarding wage transparency. Its primary goal, as it will be implemented in Poland, is to ensure equal pay for men and women performing the same or equivalent work and to reduce the gender pay gap in the Polish labor market.
For a concise overview of the directive and its implications for employers, you may want to review a dedicated summary.
What Will Change in Poland?
Key provisions Poland will be required to implement include:
- Mandatory salary information in job advertisements
- Employee rights to pay information
- Reporting requirements for larger employers
- Mechanisms to address unjustified pay gaps
Employers preparing for these changes can benefit from practical guidance tailored to the new requirements.
Timeline for Implementation
Poland must transpose the directive into national law by June 7, 2026. For Polish employers, this means:
- By June 7, 2026: Full implementation of the directive into Polish law
- June 7, 2027: First mandatory pay gap reports due from employers with 250+ employees
- 2027: First reporting cycle for employers with 150–249 employees (repeating every three years)
- 2031: First reporting cycle for employers with 100–149 employees
Poland's Legislative Journey
Poland has taken initial steps toward implementing the EU Pay Transparency Directive, though the process has faced some challenges.
In December 2024, a group of Polish Parliament members submitted a draft law to transpose part of the directive into Polish law, focusing primarily on pay transparency elements. However, on February 6, 2025, the lower house of Parliament voted against the amendments to the Labor Code that would have partially implemented the directive. As of April 2025, Poland remains in the early stages of the transposition process, with future legislative attempts expected in the coming months.
Key Requirements for Employers in Poland
When implemented, the directive will introduce several significant changes to Poland's employment landscape. Based on the directive's requirements and legislative proposals in Poland, these are the key obligations employers should anticipate:
1. Transparency in Recruitment
- Job advertisements must include the minimum and maximum salary levels for the position
- Employers may indicate that the salary is negotiable
- Information about applicable collective agreements may need to be provided
- Employers will be prohibited from asking candidates about their salary history
Asking about candidates’ salary history will soon be prohibited, making it important to rethink interview practices. Including salary ranges in job ads is also a key part of the new rules – explore the advantages and challenges of this approach
2. Employee Rights to Pay Information
- Employees have the right to request information about their individual salary level
- Employees can access average salary levels for comparable positions, broken down by gender
- Employers must respond to such requests within 14 days
- Employees are protected if they share salary information with colleagues
Transparency is not just a regulatory requirement; it can also strengthen your compensation review process.
3. Reporting Requirements for Larger Employers
- Employers with 250+ employees: Annual gender pay gap reporting starting in 2027
- Employers with 150–249 employees: Reporting every three years starting in 2027
- Employers with 100–149 employees: Reporting every three years starting in 2031
4. Gender Pay Gap Thresholds and Remediation
- Companies with an unjustifiable gender pay gap exceeding 5% for any category of employees must take corrective action
- Such employers must rectify the pay gap within 6 months or conduct a more detailed joint pay assessment
- Non-compliance may result in penalties, with fines ranging from PLN 1,000 to 30,000 for failing to provide salary information or for other violations
To learn more about how transparency directly supports efforts to close the gender pay gap, see the following analysis.
How Polish Employers Should Prepare
With implementation required by June 2026, Polish employers should start preparing now to ensure compliance. Here are the key steps:
Review and Update Recruitment Practices
- Develop a process for determining appropriate salary ranges for all positions
- Update job advertisement templates to include salary information
- Train recruiters to avoid asking about previous salary history
- Create systems for documenting and communicating collective agreement provisions to candidates
Adapting your hiring practices is essential for compliance and fairness; here are some strategies to consider.
Establish Transparent Pay Criteria
- Define clear, objective, and gender-neutral criteria for determining pay at each job level
- Document the factors used in evaluating work of equal value (skills, effort, responsibility, working conditions)
- Create accessible materials explaining these criteria to employees
- Develop a communication plan to ensure all employees understand the pay structure
Prepare for Employee Information Requests
- Establish a process for responding to employee requests for pay information
- Determine who will handle these requests and how responses will be formulated
- Create templates for providing this information consistently and compliantly
- Set up tracking systems to ensure timely responses within the 14-day requirement
Develop Pay Gap Monitoring and Reporting Capabilities
- Identify which “categories” of employees perform work of equal value
- Establish systems for collecting and analyzing compensation data by gender
- Set up processes for calculating required gender pay gap metrics
- Create templates for internal and external reporting
- Develop action plans for addressing pay gaps that exceed the 5% threshold
Conducting a thorough pay equity analysis is a practical step in meeting new reporting requirements.
Checklist: Step-by-Step Preparation Guide
To help employers in Poland prepare systematically for the new requirements, use this checklist:
- Recruitment Transparency Preparation
- Review current job advertising processes
- Develop salary range guidelines for all positions
- Update job advertisement templates
- Train recruiting teams on new requirements
- Remove salary history questions from interviews
- Pay Structure Analysis
- Document criteria used for determining pay at each level
- Ensure all criteria are gender-neutral and objective
- Define job categories of “equal value” using objective factors
- Review and update job descriptions to reflect work value accurately
- Document the relationship between job categories and pay levels
- Information Sharing Procedures
- Establish process for handling employee pay information requests
- Create templates for responding to information requests
- Develop communication plan for informing employees of their rights
- Prepare systems for tracking and timely response to requests
- Train HR teams on handling sensitive pay information
- Pay Gap Analysis and Reporting
- Set up data collection systems for compensation analysis
- Establish methodology for calculating gender pay gaps
- Prepare templates for internal and external reporting
- Develop action plans for addressing significant pay gaps
- Create review cycles to monitor progress on closing pay gaps
- Policy and Documentation Updates
- Review employment contracts to remove pay secrecy clauses
- Update compensation policies to reflect transparency principles
- Develop anti-discrimination procedures related to pay
- Create documentation of all pay-related processes
- Establish record-keeping systems for compliance evidence
For a ready-to-use checklist to support your preparations, you can download our newly updated checklist!
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