[co-authors: Lorraine Matthews, Emilia Mobius]
On 16 December 2025, Poland published a draft bill implementing the EU Pay Transparency Directive (Directive (EU) 2023/970). This development follows assumptions previously outlined in Poland’s Draft Pay Transparency Law to Mandate Job Evaluations Under New Government Tool and provides employers with clear obligations ahead of the directive’s implementation deadline. In line with European Union regulations, the law is expected to enter into force on 7 June 2026. Poland has already began implementing the directive with transparency measures entering into force from 24 December 2025. Polish law will require employers to provide transparent information to job applicants and to ensure a fair and gender-neutral recruitment process.
Quick Hits
- Employers in Poland would be required under a draft bill to implement the EU Pay Transparency Directive to evaluate jobs using four statutory criteria: skills, effort, responsibility, and working conditions.
- Under the draft bill, employee pay comparisons can include other employers under a single source of remuneration rules.
- Employers would be required to inform all employees annually by March 31 of their right to request individual and gender-based pay information.
- Unjustified pay gaps of 5 percent or more may trigger remedial action, joint wage assessments, and financial penalties of up to PLN 50,000.
The draft bill would require employers to assess the value of work performed in their organisation using four statutory criteria: skills, effort, responsibility, and working conditions, and may introduce additional, job-specific criteria where relevant. Thus, employers would be required to determine the categories of employees performing equal work or work of equal value and establish transparent criteria for remuneration, salary levels, and salary increases. These criteria would have to be made accessible to employees, subject to limited exceptions for employers with fewer than fifty employees. The assessment of equal work or work of equal value can also include employees of other employers that share a single source of remuneration rules, such as internal regulations within a capital group. Where trade unions operate, employers and the unions would have to agree upon remuneration criteria.
The draft bill also would introduce information obligations. Upon request, employees would be entitled to receive information on their individual pay level as well as the average pay levels by gender for the relevant employee category, within thirty days. Employers would have to inform employees by 31 March each year of their right to make such requests, and it would not be possible to prohibit employees from disclosing information about their remuneration.
In addition, employers with at least one hundred employees, calculated on a full-time equivalent basis including temporary workers, would be required to prepare gender pay gap reports. Where an unjustified pay gap of 5 percent or more is identified within a category of worker, employers would generally have six months to take effective remedial action. Failure to do so could result in a mandatory joint wage assessment with trade unions or employee representatives.
Under the bill, employees may claim compensation of at least the minimum for violations of equal pay, including outstanding pay, benefits in kind, lost profits, damages from intersectional discrimination, and interest for delay. Employers would face fines ranging from PLN 3,000 to PLN 50,000 for noncompliance with the law.
Employers are encouraged to stay informed about the implementation process in their respective jurisdictions.