Poland has released a new draft law implementing the EU Pay Transparency Directive (Directive (EU) 2023/970), giving employers more clarity on how pay transparency rules may work in practice.
The updated proposal, published in May 2026, adds operational detail around pay gap reporting, equal value assessments, reporting calculations, and remediation obligations.
What’s Included in the New Draft?
The latest proposal introduces:
- More detailed pay gap reporting methodologies
- Clarification on hourly pay calculations
- Guidance on excluded compensation elements
- Additional detail on equal value assessments
- Potential inclusion of temporary workers in reporting
- More clarity around the 5% unexplained pay gap trigger
This moves Poland closer to practical implementation rather than high-level legal transposition.
The direction is now clear: employers should prepare operationally before the law is final.
Recruitment Transparency Rules Are Already Active
Some EU Pay Transparency rules are already in force in Poland.
Since December 2025, employers must:
- Share salary ranges or starting pay with candidates
- Use gender-neutral job advertisements
- Avoid asking candidates about salary history
The new draft focuses on the remaining obligations, including internal transparency and gender pay gap reporting.
Read more about the EU Pay Transparency Directive here
The Biggest Challenge: Equal Value
Like the Directive itself, Poland’s draft requires employers to assess equal work and work of equal value using criteria such as:
- Skills
- Responsibility
- Effort
- Working conditions
For many employers, this means compensation structures, job architecture, and pay-setting processes may need significant review.
Organisations will likely need:
- Clear job categorisation
- Consistent evaluation frameworks
- Audit-ready documentation
- Transparent pay-setting criteria
The compliance challenge is no longer theoretical — it is operational.
The 5% Pay Gap Trigger
The draft includes the Directive’s 5% unexplained pay gap threshold.
If employers identify a gap of 5% or more within a category of workers and cannot objectively justify it, they may need to:
- Conduct remediation measures
- Work with employee representatives
- Complete a joint pay assessment
What Employers Should Do Now
Even before the legislation is finalised, employers should start preparing.
Priority areas include:
- Reviewing job architecture and equal value methodology
- Auditing compensation and payroll data
- Testing gender pay gap analytics
- Reviewing recruitment transparency processes
- Improving documentation and governance
Poland’s latest EU Pay Transparency draft shows how quickly pay transparency is becoming an operational issue rather than a future compliance project. Employers that begin reviewing pay structures, job architecture, and reporting readiness now will be in a much stronger position as national implementation accelerates across Europe.
