Poland’s Draft Pay Transparency Law to Mandate Job Evaluations Under New Government Tool

Quick Hits

• Rather than simply amending the Labour Code, the Polish government plans to implement EU Pay Transparency Directive 2023/970 in a standalone piece of legislation.
• Employers will be obliged to go through a process of job evaluation, consisting of four core basic criteria. The plan will also see the introduction of a “Job Evaluation Tool.”
• A failure to comply with the changes may result in a fine of up to PLN 60,000.
• Generally, the draft law is likely to align with the provisions set out in the EU Pay Transparency Directive.

The Polish government has strongly affirmed that employers will be required to undertake job evaluations for the purpose of determining whether employees perform work of equal or comparable value. In this regard, the proposal introduces a new analytical tool for job evaluations, intended to support employers in meeting this obligation. However, employers retain the discretion to adopt an alternative methodology, provided that such methodology is analytical, gender-neutral, and objectively justified.

Importantly, any job evaluation process, whether based on the government’s proposed tool or a method selected by the employer, must address four mandatory criteria: skills, effort, level of responsibility, and working conditions. These criteria must be applied uniformly across all positions. As a result, certain commercial job evaluation models may not align with the prescribed requirements. Employers that intend to rely on such models may be required to modify or replace them to ensure compliance.

The tool accommodates a maximum of eighty-five positions and twenty-six categories, which may present operational challenges for larger employers. It will therefore fall to individual employers to assess whether the proposed tool is adequate for their organisational structure or whether an alternative method is necessary.

Failure to conduct job evaluations may expose employers to fines of up to PLN 60,000 (approximately USD $16,400). Such penalties may be imposed where an employer, or a person acting on the employer’s behalf, fails to:

• assess the value of individual job positions or categories of work,
• provide employees with information concerning applicable pay criteria,
• furnish employees with specified pay information upon request,
• prepare a gender pay gap report or conduct a joint pay assessment where required, or
• implement appropriate remedial measures to address any identified gender pay gap.

A full draft bill is expected to be released for public consultation imminently. Current indications are that the draft bill will be adopted by the Council of Ministers and subsequently referred to Parliament in Poland in the second quarter of 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 European Union can be found using Ogletree Deakins’ 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”, “Netherlands Announces Delay in Implementation of the EU Pay Transparency Directive.” and “The June 2026 EU Pay Transparency Directive Implementation Deadline Looms.”

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, Pay Equity Practice Group, 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.

Emilia Mobius, a paralegal in the London office of Ogletree Deakins, contributed to this article.

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