On 25 November 2025, the Polish government published the principal assumptions intended to underpin forthcoming legislation implementing the outstanding provisions of the EU Pay Transparency Directive 2023/970. The government has commenced the process of transposing the directive into national law. The first measures will be introduced by way of amendments to the existing Labour Code, and will come into effect 24 December 2025.
Quick Hits
- Rather than simply amending the Labour Code, the Polish government plans to implement EU Pay Transparency Directive 2023/970 in a standalone piece of legislation.
- Employers will be obliged to go through a process of job evaluation, consisting of four core basic criteria. The plan will also see the introduction of a “Job Evaluation Tool.”
- A failure to comply with the changes may result in a fine of up to PLN 60,000.
- Generally, the draft law is likely to align with the provisions set out in the EU Pay Transparency Directive.
The Polish government has strongly affirmed that employers will be required to undertake job evaluations for the purpose of determining whether employees perform work of equal or comparable value. In this regard, the proposal introduces a new analytical tool for job evaluations, intended to support employers in meeting this obligation. However, employers retain the discretion to adopt an alternative methodology, provided that such methodology is analytical, gender-neutral, and objectively justified.
Importantly, any job evaluation process, whether based on the government’s proposed tool or a method selected by the employer, must address four mandatory criteria: skills, effort, level of responsibility, and working conditions. These criteria must be applied uniformly across all positions. As a result, certain commercial job evaluation models may not align with the prescribed requirements. Employers that intend to rely on such models may be required to modify or replace them to ensure compliance.
The tool accommodates a maximum of eighty-five positions and twenty-six categories, which may present operational challenges for larger employers. It will therefore fall to individual employers to assess whether the proposed tool is adequate for their organisational structure or whether an alternative method is necessary.
Failure to conduct job evaluations may expose employers to fines of up to PLN 60,000 (approximately USD $16,400). Such penalties may be imposed where an employer, or a person acting on the employer’s behalf, fails to:
- assess the value of individual job positions or categories of work,
- provide employees with information concerning applicable pay criteria,
- furnish employees with specified pay information upon request,
- prepare a gender pay gap report or conduct a joint pay assessment where required, or
- implement appropriate remedial measures to address any identified gender pay gap.
A full draft bill is expected to be released for public consultation imminently. Current indications are that the draft bill will be adopted by the Council of Ministers and subsequently referred to Parliament in Poland in the second quarter of 2026.