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Poland: First Steps Taken to Implement EU Pay Transparency Directive

By - - Employment Law

Poland has accelerated the implementation of parts of the EU Pay Transparency Directive.

The new rules, now come into force at  the end of 2025, six months from publication.

Employers now have less time to prepare than the EU’s 7 June 2026 deadline.

Key Requirements for Employers

The new rules require pay transparency during recruitment. Employers must now:

  • Disclose full remuneration details for advertised roles, including all pay components  and any additional benefits. This must be presented as either a fixed amount or a range, based on objective, gender-neutral criteria.
  • Provide terms of relevant collective agreements or internal pay policies, where applicable.
  • Deliver this information in writing (paper or electronic) at one of three stages:
    • In the job advert;
    • Before the interview (if not already disclosed);
    • Before the employment contract is signed (if not previously disclosed).

Additionally, job titles and adverts must be gender-neutral, and employers are prohibited from asking candidates about their current or past pay.

Practical Implications

Key actions for employers include:

  • Auditing and cataloguing remuneration structures. Employers must identify and document all pay components for each role, ensuring alignment with collective agreements or internal pay frameworks.
  • Establishing objective pay criteria. Remuneration must be benchmarked against comparable roles, considering skills, effort, responsibility, working conditions, and other relevant factors. These criteria must be applied consistently and without gender bias.
  • Updating recruitment materials. Job advert templates and internal recruitment protocols will need to be revised to reflect the new disclosure obligations.
  • Training and internal alignment. HR teams and hiring managers must be trained on the new requirements. Multinational employers may need to coordinate implementation across jurisdictions to ensure consistency.

Strategic Considerations

Employers will need to manage the timing and format of remuneration disclosures, balancing legal compliance with internal communication strategies and external competitiveness. Transparency with candidates may prompt questions from existing staff, so internal messaging should be planned accordingly.

While this amendment only covers part of the EU Directive, the government is still working on transposing the remaining provisions, however no draft legislation has been published yet.

Given the accelerated timeline, employers should act now to ensure compliance and avoid disruption. Early preparation will also position businesses to respond effectively to the broader transparency and equal pay obligations still to come.

This is a high level general update only. Legal advice should be obtained on specific circumstances.
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