From 24 Dec 2025, the EU Pay Transparency Directive takes effect in Poland. Employers must disclose salary ranges in recruitment, use gender-neutral ads, and prepare for pay gap reporting and stricter compliance rules by June 2026.

Why these changes?

As of 24 December 2025, certain provisions of the EU Pay Transparency Directive (EU 2023/970) will come into force in Poland.

The aim of the Directive is to increase pay transparency, prevent pay discrimination – particularly in the context of the so-called gender pay gap, i.e. the wage disparity between women and men – and ensure equal treatment in recruitment processes by enabling candidates to conduct informed negotiations.

What will change from 24 December 2025?

The amendments to Article 18(3ca) of the Labour Code primarily concern the recruitment stage and introduce new employer obligations towards job applicants, gender-neutral language in job advertisements, and a ban on asking candidates about their previous earnings.

Information on remuneration for job applicants

From 24 December 2025, every employer will be required to provide the candidate with information on:

• the starting salary or its range,
• relevant provisions of the remuneration regulations or collective agreement (if applicable).

The information must relate to the specific position. If a collective agreement or remuneration regulations apply, the relevant provisions concerning the position must be presented.

Timing and form of providing remuneration information

The employer must provide the candidate with remuneration details in paper or electronic form to ensure informed and transparent negotiations.

This information may be provided:

1. in the job advertisement – if the company decides to disclose pay ranges upfront,
2. before the interview – if the information was not included in the advertisement,
3. before employment begins – if the candidate has not received the information earlier.

Gender-neutral job advertisements and titles

The amendment to the Labour Code introduces an obligation to create gender-neutral job advertisements. Employers must ensure that job titles and the entire recruitment process do not suggest gender preferences and are conducted in a non-discriminatory manner.

The regulations do not specify exactly what such neutrality should look like – detailed guidelines and case law will be developed in due course. In the meantime, it is advisable to follow a few principles:

• use both feminine and masculine forms (e.g. in Polish: specjalista/specjalistka),
• add the abbreviation (m/f) after the job title,
• use impersonal forms (e.g. person managing a team),
• use English job titles, which are automatically gender-neutral (e.g. Project Manager).

Violation of transparency and neutrality rules – consequences for employers

Currently, violating transparency and neutrality rules does not entail a fine, as the Labour Code does not provide for such penalties and the relevant provisions have not been amended. However, this will change in June 2026, when the law implementing the Directive on pay transparency is fully incorporated into Polish legislation.

It should be noted that a prospective employee may always sue the employer for damages due to a breach of the principle of equal treatment in employment. The employee is entitled to compensation of no less than the minimum wage.

What awaits employers from 7 June 2026?

Full implementation of Directive 2023/970 will require companies to organise their remuneration structures and prepare for new reporting obligations.

The Directive also provides for enhanced employer liability – including the possibility of financial penalties and shifting the burden of proof to the employer in pay-related disputes.

To meet upcoming requirements, companies should already begin job evaluation, build or update remuneration systems, conduct pay audits, and ensure consistent rules for awarding pay across the organisation. In practice, this means organising pay data, clearly defining job levels and salaries, and implementing solutions to facilitate future reporting.

The upcoming changes are an excellent opportunity to strengthen pay governance, increase transparency, and prepare HR and payroll structures for new EU-wide standards.