On 24 December 2025, amendments to the Polish Labour Code will come into force, introducing a mandatory pay transparency requirement. This will significantly impact recruitment processes and necessitate the implementation or restructuring of remuneration frameworks. The reform aims to enhance transparency in pay policies, reduce discrimination, and promote equal career opportunities for women and men. These changes implement the EU Directive 2023/970 of the European Parliament and Council, preparing businesses for full transposition by 7 June 2026.
Mandatory disclosure of salary information to candidates
One of the key requirements is the obligation to provide candidates with clear salary information. This applies to all new recruitment processes and cases where salary details were not disclosed in the job advertisement. The information should include:
- The starting salary amount or its range (salary bands),
- All components of remuneration and additional benefits – both monetary (bonuses, seniority allowances, functional or jubilee bonuses) and non-monetary (private healthcare, sports card, company car for private use, phone, laptop, additional leave, etc.),
- Social benefits and allowances.
Employers may share this information in various ways: directly in the job posting, before the interview, or at the latest before signing the employment contract. Although the law does not require formal documentation of this disclosure, it is advisable to keep proof, such as an email or a signed candidate statement.
Salary bands and objective criteria
The new regulations require salary ranges to be based on clear, objective, and gender-neutral criteria. This means that two individuals performing comparable work with similar qualifications and achievements should fall within the same pay range, regardless of gender, age, or other personal characteristics.
Companies should therefore conduct a pay audit, implement job evaluation based on four criteria, and develop a consistent pay grid to avoid unjustified discrepancies and potential employee claims.
The definition of “remuneration” is crucial in audits, as it must include not only the base salary but also supplementary or variable components. The term should cover all elements payable under law, collective agreements, or established practice in each Member State.
Ban on asking about previous salary
From 24 December 2025, employers will no longer be allowed to ask candidates about their previous remuneration. Both direct questions and indirect attempts to obtain such information are prohibited. This measure aims to prevent perpetuating pay inequalities and enable candidates to negotiate salaries based solely on competencies and market value.
Gender-neutral language in job ads
Employers must also ensure job advertisements are formulated in a gender-neutral and non-discriminatory manner. Prohibited are terms suggesting preferences regarding gender, age, appearance, nationality, or other personal traits. Acceptable practices include:
- Using both gender forms: “manager/manageress”, “specialist/specialistka”,
- Adding M/F indicators: “analyst (M/F)”,
- Generic descriptions such as “person for the position…” or “we are hiring a person for customer service”,
- Describing tasks instead of job titles.
This approach promotes equal opportunities and mitigates legal risks.
Employees’ right to information
The changes also apply to current employees, who will have the right to request:
- Their own remuneration details,
- Average pay levels for positions within the same category or of equivalent value, broken down by gender,
- The criteria for determining pay, promotions, and raises, which must be objective and gender-neutral.
This empowers employees to monitor pay equity and protect their rights.
Pay gap reporting
Companies employing at least 100 staff will be required to regularly report gender pay gaps:
- Large companies (250+ employees) – annually,
- Medium-sized companies (100–249 employees) – every three years.
If discrepancies exceed 5% without objective justification, employers must implement a corrective action plan. Reports must include various criteria, such as variable components and employee categories. The first reports will cover data for 2026, making current pay decisions critical.
Pay transparency in Poland - penalties and risks
Non-compliance will result in financial penalties. Fines ranging from PLN 2,000 to PLN 60,000 may be imposed for failure to conduct job evaluation, submit reports, or implement other required measures. Additionally, in disputes over unequal pay, the burden of proof will shift to the employer, who must demonstrate the objectivity of applied criteria.
How can companies prepare?
To effectively implement these changes, businesses should start now by:
- Reviewing current pay levels and components,
- Identifying potential pay gaps,
- Updating recruitment policies,
- Training HR teams,
- Revising pay grids and internal regulations,
- Informing employees about new rights and procedures.
The introduction of pay transparency on 24 December 2025 marks a milestone in shaping a modern, transparent, and fair pay policy in Poland. Companies that begin preparations early will not only avoid legal risks but also strengthen their market position by building trust among candidates and employees. Comprehensive audits, standardized job descriptions and salary bands, training, and thoughtful communication will enable businesses to turn pay transparency into a competitive advantage.
Ready to prepare your organization for pay transparency?
Start now by auditing your remuneration structure, updating recruitment policies, and training your HR teams. Contact us today to learn how we can help you implement compliant and competitive pay practices that strengthen your employer brand.
