Poland Moves Ahead on Pay Transparency

December 2025 was a busy month in Poland on the pay transparency front with the country taking significant steps toward implementing the EU Pay Transparency Directive. Effective 24 December 2025, new rules now apply to the recruitment process in Poland, requiring employers to disclose starting pay or salary ranges to candidates and use gender-neutral job titles. Meanwhile, a draft bill published on 16 December 2025 outlines comprehensive measures to enforce pay equity across the workforce, including mandatory job evaluations, annual wage gap calculations for larger employers, and new employee rights to pay information. In this article, we take a look at the new obligations that have taken effect and the broader obligations on the horizon.

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The Law of 4 June 2025 amending the Labour Code came into force on 24 December 2025. Its scope is limited to pay transparency during recruitment and so it only partially implements the EU Pay Transparency Directive.

Employers must now inform candidates of starting pay or salary ranges either in job advertisements or, at the latest, before the interview or the employment agreement is concluded. In addition, job titles and adverts must be gender-neutral, applicants must not be asked about their current or previous pay and recruitment processes must be free of discrimination.

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Separately, on 16 December 2025, the Polish Government published a draft bill that seeks to comprehensively implement the other provisions of the directive. It is expected to become effective on 7 June 2026 but could be subject to change before it is finalised.

Under the draft law, and among other obligations:

• all employers will be required to conduct job evaluations taking into account criteria under both the Polish Labour Code and the Directive (mandatory criteria being skills, effort, responsibility and working conditions) to establish the applicable job categories;

• employers will also need to ensure that any differences in remuneration for employees performing the same work or work of equal value is justified by objective, gender-neutral and unbiased criteria;

• employees will be granted new rights to pay information, with reduced timeframes (when compared with the Directive) for employers to respond;

• employers with at least 100 employees, including temporary workers, will need to calculate the wage gap annually;

• reporting obligations will then apply to employers with 100–249 employees (they must report every three years) and to those with more than 250 employees (they must report every year); and

• if the wage gap in a given category is ≥ 5% and there is no objective justification, employers will have six months to implement remedial measures, in co-operation with trade unions.

Violation of most of the obligations under the draft legislation will be punishable by a fine of up to PLN 50,000 (approximately EUR 11,875).

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The Government has also published a draft tool aimed at assisting employers with ‘job evaluation’, the process by which they can determine the relative value of roles within their organisation for the purposes of the Directive. The draft tool is formatted as a downloadable Excel document. The tool is voluntary and open for feedback until 9 January 2026.

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These developments signal a major shift in pay transparency obligations for Polish employers. While the initial recruitment-related requirements are relatively straightforward, the forthcoming rules will demand significant preparation – particularly around job evaluation, pay structure reviews, and reporting systems. Employers should start assessing their current practices, engaging with trade unions where required, and planning for compliance well ahead of the June 2026 deadline to avoid penalties and reputational risks.

*Lewis Silkin

**Raczkowski