Poland: The EU Pay Transparency Directive

Implementation and actions

What is the current implementation status and timing? (July 2026)

The implementation of the Directive remains partial.

To date, only the requirements relating to pay transparency prior to employment were enacted, with effect from 24 December 2025 (see below for more details).

The remaining provisions of the Directive have not yet been transposed into national law and the 7 June 2026 transposition deadline was missed in respect of these provisions. A draft bill addressing the outstanding requirements is understood to be in progress, with full implementation expected during 2026.

What preparatory steps are you advising clients to take, including ensuring they have access to the required data?

Employers should start preparing for the Directive by:

• Analysing the organisation's remuneration structure, including all components of pay and other benefits granted to employees;
• Reviewing roles in terms of the type of work, scope of duties and responsibilities and carrying out a job evaluation based on the "equal work" or "work of equal value" criterion; and
• Making sure that all information is available digitally.

Additional recommended steps:

• Review job titles across the organisation to ensure gender neutral terminology
• Decide when and how to inform candidates about remuneration and prepare standard disclosure wording 
• Assess pay grades and pay structures against the categories of equal work and work of equal value as defined by the Directive
• Collect information on how pay differences may be justified on gender-neutral grounds
• Eliminate any unjustified differences in remuneration and benefits, and
• Identify any gender pay gap and take action to address it.

Please click here for more on actions employers can take in preparing for the Directive.

Implementing the Directive's requirements

Which workers are in scope?

It is anticipated that the implementation of the Directive in Poland will cover only employees.

Who will be workers' representatives?

According to the draft implementing legislation, "workers' representatives" will refer to company level representatives, namely company-level trade union organisations and ad hoc employee representatives elected for a specific issue.

Where an employer does not have any workers' representatives for the purposes of the Directive, it will be required to initiate a process to elect ad hoc employee representatives.

Are there any proposals around the methodology and tools for assessing "equal value"?

Polish legislation already defines the concept of work of equal value – this refers to work which requires employees to have comparable professional qualifications, confirmed by documents provided for under separate regulations or by professional practice and experience, as well as comparable levels of responsibility and effort.

The proposed new provisions introduce changes in this regard. Under the new rules, work of equal value will be assessed collectively on the basis of mandatory criteria – skills, effort, scope of responsibility and working conditions – and potentially also sub-criteria or additional criteria established by the employer that are relevant to a particular position or type of work. Further criteria may be applied provided they are objective, gender neutral and free from direct or indirect sex based discrimination, including soft skills where required for a given role.

How is pay defined?

The draft implementing legislation defines "pay" as encompassing all components of remuneration, regardless of name or nature, as well as other work-related benefits granted in monetary or non-monetary form – including basic salary, allowances, bonuses, incentive payments and non-material benefits such as private medical care.

How are the requirements for transparency for job applicants being implemented?

Article 5 of the Directive (pay transparency prior to employment) was implemented into Polish law as of 24 December 2025. Under the new law:

• employers are obliged to provide candidates regarding their starting remuneration (or range thereof), alongside relevant provisions of a collective bargaining agreement/remuneration regulations applicable to the position (if applicable to a given employer)
• this information must be provided in the vacancy notice or if not included in that notice, before the interview or, at the latest, before the employment relationship is established; in each case sufficiently in advance to allow the candidate to negotiate in an informed and transparent manner
• the information must be provided in writing or electronic form.

The new law also provides that job titles will have to be gender neutral and employers will not be entitled to ask candidates about their salary in current and former workplaces. 

How are the requirements for transparency for workers being implemented?

Polish law will need to accommodate these new obligations.

Current position

At present, Polish law mandates equal pay for equal work or work of equal value between female and male employees. There are no specific transparency obligations.

How are the gender pay reporting requirements being implemented?

It is anticipated that Polish law may, in line with the Directive, exempt employers with fewer than 50 employees from the obligation to provide workers with information on pay progression criteria.

Current position

There are no current reporting requirements in Poland.

When counting workers for the purposes of the Directive's pay reporting thresholds, will only workers of a particular "legal entity" be in scope?

The draft implementing legislation refers to the legal entity rather than adopting a wider group of companies approach. This is the most common approach for threshold-based obligations in Poland.

Do we have details on how the requirement for a joint pay assessment will be implemented?

The draft implementing legislation provides that a joint pay assessment must be carried out where:

• the pay gap report identifies a gender pay gap of at least 5% in absolute terms in any category of employees
• the employer fails to justify this gap on objective, gender-neutral grounds, and 
• the employer fails to take effective remedial action. 

The assessment must be conducted with the participation of employee representatives (trade unions, or in their absence, ad hoc employee representatives).

Do we have details as to how the Directive obligations will be enforced and potential sanctions?

The draft implementing legislation provides that non-compliance with the Directive's obligations will constitute a petty offence punishable by a fine of between PLN 2,000 and PLN 60,000.

Are there any tools or guidance available to support employers?

At present there is no non-statutory guidance providing indications on the gender pay reporting process.