Poland: Pay Transparency Measures Employers Must Implement by 24 December 2025

Quick Hits

• The legislative goal in Poland mirrors the European Union’s Pay Transparency Directive’s core objectives: reducing gender‑based pay discrimination by making pay systems more transparent and comparable.
• Further measures covering employee information rights and gender pay gap reporting are expected by 7 June 2026 in line with the Directive’s implementation deadline.
• While legislation is still to be finalised, it is likely that noncompliance will result in administrative fines.

New Obligations in Recruitment

From 24 December 2025, employers recruiting in Poland must meet specific transparency standards at the candidate stage:

• Provide the proposed remuneration for the role (either a specific amount or a range) based on objective, gender‑neutral criteria, together with any relevant pay provisions from collective bargaining agreements or remuneration regulations. This information must be provided in writing, through paper or electronic form, and with sufficient time to allow informed negotiations. Employers may include this information in the job advertisement, provide it before an interview where there was no job advertisement, or at the latest, before an employment relationship is established.
• Use gender‑neutral job titles and ensure job vacancy notices and recruitment processes are conducted in a nondiscriminatory manner.
• Do not ask candidates about their current or previous pay. Questions about salary history will be unlawful under the amended Labour Code. However, employers may ask about salary expectations.

What’s Next?

Additional obligations for employers, in line with the Directive, are expected as Poland continues transposition by 7 June 2026. These obligations include access to information on individual pay levels and average pay broken down by gender and those carrying out the same work or work of equal value, as well as clearer disclosure of the objective, gender‑neutral pay criteria used to determine the employer’s pay scales.

Employers in Poland with 150 or more employees in a single legal entity will also be subject to mandatory gender pay gap reporting, with the first reporting period set to commence in 2027 based on 2026 pay data. Further information on reporting obligations can be found in our recent article, “The June 2026 EU Pay Transparency Directive Implementation Deadline Looms.”

Employers operating in Poland may want to assess their recruitment processes and update documentation to meet the new Polish requirements now ready for the 24 December deadline, while preparing for the broader framework set to follow in June 2026.

Employers are encouraged to stay informed about the implementation process in their respective jurisdictions. Information and updates on the progress of the directive’s implementation across the EU can be found using Ogletree Deakins’ EU Pay Transparency Directive – Member State Implementation Tracker.

For more on the EU’s Pay Transparency Directive, see our previous articles, “EU Pay Transparency Directive: Updates on Implementation Across Member States,” “Preparing for the EU’s Pay Transparency Directive,” “EU Pay Transparency Directive: ‘Equal Pay for Equal Work or Work of Equal Value’,” “Implementing the EU Pay Transparency Directive in Malta—New Obligations Effective From 27 August 2025,” and “Netherlands Announces Delay in Implementation of the EU Pay Transparency Directive.”

Further information can also be found by listening to our podcast “Understanding the EU Pay Transparency Directive: What Employers Need to Know.”

Ogletree Deakins’ London office and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Cross-Border, Pay Equity, and Workforce Analytics and Compliance blogs as additional information becomes available.

Daniella McGuigan is a partner in the London office of Ogletree Deakins and co-chair of the firm’s Pay Equity Practice Group.

Lorraine Matthews, a practice assistant in the London office of Ogletree Deakins, contributed to this article.

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