On 24 December 2025, the first set of pay transparency regulations will come into force, aligning Polish labour law with the EU Pay Transparency Directive. These changes will apply to all employers and will significantly affect recruitment processes, pay policy design, and communication with employees.
Reasons for the changes
According to Eurostat, women in the EU earn on average 12% less than men. In Poland, the gender pay gap is smaller (7.8%), but still material. Limited transparency in remuneration systems makes it difficult to identify unjustified disparities. The new regulations aim to address this by introducing clear pay rules and mandatory reporting obligations.
What will change as of 24 December 2025?
For all employers:
- mandatory disclosure of salary ranges in job advertisements,
- a ban on asking candidates about their previous pay,
- employees’ right to information on pay-setting criteria and average salaries for comparable roles,
- an obligation to present total compensation, including benefits.
Starting in 2026, employees will gain broader access to information about their compensation, and companies will be required to streamline their pay and benefits policies.
Additional obligations for employers with at least 100 employees
- annual reporting of the gender pay gap (first report in 2027 for the year 2026),
- analysis and explanation of unjustified pay disparities,
- joint pay assessments with employee representatives,
- development of structured and transparent pay grids.
How should employers prepare?
Employers should review their compensation structures, update job architecture, adjust recruitment processes, implement tools for data monitoring, and equip managers to conduct pay discussions under the new framework. This is also the right time to harmonise benefit policies.
Consequences of non-compliance
Failure to comply will result in significant financial penalties, exposure to employee claims, and serious reputational risks. Importantly, salary decisions made after 1 January 2026 will directly affect the data used in the first mandatory report.
Although the new regulations introduce additional duties, they also present an opportunity for employers to build a more modern, transparent, and attractive organisation. Pay transparency strengthens trust and employee engagement — and that is a tangible business advantage.
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