Pay Transparency Directive in Poland

7 June 2026 is the deadline for transposing the provisions of the Pay Transparency Directive into national law. The directive aims to strengthen the principle of equal pay for men and women performing the same work or work of equal value by introducing greater pay transparency and enforcement mechanisms.

Although the Polish bill addressing this issue is still at the consultation stage, it is expected to enter into force on that exact date.

The Polish bill introduces the following key obligations:

• the employer’s obligation to provide employees with information on remuneration criteria, salary levels, and rules governing pay progression and increases;
• the employer’s obligation to prepare gender pay gap reports (applicable to employers with at least 100 employees);
• the employee’s right to request information on individual remuneration, as well as average remuneration levels for comparable categories of employees, broken down by gender;
• the removal of pay secrecy restrictions where such restrictions may hinder the application of equal pay principles.

Concerns raised by administrative authorities and public organisations suggest that the current draft requires further refinement. The most common criticisms are that the proposed rules allow overly broad access to personal data without sufficient safeguards for anonymisation, and that certain definitions remain unclear, which could affect employers’ reporting obligations.

The bill also introduces an additional mechanism not included in the directive, namely the evaluation of work of a specific nature or in a specific role (job evaluation) based on criteria and sub-criteria adopted by the employer in accordance with the definition of work of equal value contained in the Labour Code. This is regarded as extending employers’ obligations beyond those set out in the directive.

Close monitoring of regulatory developments and timely adaptation of internal processes and policies will be critical to ensure full compliance with the new obligations.

For more details and assistance, get in touch with Antonina Zemska or Justyna Jóźwiak.