Poland Continues the Implementation of the EU Pay Transparency Directive

Poland has taken several important steps towards implementing the EU Pay Transparency Directive. Since December 2025, new rules on pay transparency in recruitment have already been in force, while a more comprehensive legislative proposal designed to implement the Directive's remaining requirements is still being processed by the Polish government and parliament. The aim is for the full legislation to enter into force by 7 June 2026, in line with the EU deadline.

What Is Already in Force?

Salary Information for Candidates

Since 24 December 2025, employers have been required to inform candidates about the salary or salary range applicable to a position. This information may be provided in the job advertisement or no later than before the job interview.

Ban on Questions About Previous Pay

Employers may no longer ask candidates about their current or previous salary. The purpose is to prevent historical pay inequalities from being carried over between employers.

Gender-Neutral Job Advertisements

Job advertisements and job titles must be gender-neutral, and recruitment processes must be conducted without discrimination.

What Does the Upcoming Legislative Proposal Include?

The legislative proposal published by the Polish government in December 2025, and subsequently updated during 2026, is intended to implement the remaining provisions of the EU Pay Transparency Directive.

Right to Pay Information

Employees will have the right to request information about their own pay as well as average pay levels, broken down by gender, for workers performing the same work or work of equal value. Employers are expected to have 30 days to provide this information.

Objective and Gender-Neutral Pay Structures

Employers will be required to be able to explain the criteria used to determine pay and career progression. These criteria must be objective, transparent, and gender-neutral.

Job Evaluation and Classification

Employers will need to identify and document which roles constitute the same work or work of equal value, based on factors such as skills, responsibility, effort, and working conditions.

Pay Reporting

Employers with at least 100 employees are expected to be subject to pay gap reporting requirements. Companies with 250 or more employees will be required to report annually, while companies with 100 to 249 employees will report every three years.

Joint Pay Assessments

Where an unexplained pay gap of at least 5% is identified within a category of workers performing work of equal value, employers may be required to conduct a joint pay assessment together with employee representatives.

Status: What Happens Next?

Poland has already implemented the Directive's recruitment transparency requirements, but the full implementation process is still ongoing. The government published a comprehensive legislative proposal in December 2025, and an updated version was presented in April 2026. The proposal is still under review, and certain details may change before the legislation is finally adopted.

As a result, Poland has not yet implemented all elements of the EU Pay Transparency Directive, but the country is in the final stages of the legislative process ahead of the EU deadline of 7 June 2026.

What Does This Mean for Employers?

Polish employers should already begin preparing for the upcoming requirements by:

• reviewing pay structures and pay-setting criteria;
• ensuring recruitment processes comply with the new transparency requirements;
• preparing systems for pay gap reporting and analysis;
• conducting or planning job evaluations;
• updating internal policies and guidelines relating to pay transparency.

Organisations that begin preparations early will be better positioned to comply with the new requirements once the full legislation enters into force.

Follow along with the Poland EU directive implementation here.