Starting 24 December 2025, amendments to the Polish Labour Code will introduce mandatory pay transparency. This change will reshape recruitment practices in Poland and require companies to establish or revise their remuneration structures. The reform is designed to improve clarity in compensation policies, reduce discrimination, and ensure equal opportunities for men and women. These provisions implement the EU Directive 2023/970, preparing businesses for full compliance by 7 June 2026.
Clear salary information for candidates
A major requirement of the new law is to provide candidates with transparent salary details. This applies to all recruitment processes where pay was not disclosed in the job posting. Employers must share:
- The starting salary or its range (salary brackets),
- All pay components and benefits – both financial (bonuses, seniority or functional allowances, jubilee awards) and non-financial (private healthcare, sports card, company car for private use, phone, laptop, extra leave, etc.),
- Social benefits and allowances.
This information can be communicated in the job ad, before the interview, or at the latest prior to signing the contract. While documentation is not legally required, keeping proof (e.g., email or signed statement) is recommended.
Salary ranges based on objective criteria
Salary bands must be based on clear, gender-neutral, and objective standards. Employees performing comparable work with similar skills and achievements should fall within the same range, regardless of gender, age, or other personal attributes.
To comply, companies should conduct a pay audit, implement job evaluation using four criteria, and create a consistent pay structure to prevent unjustified gaps and potential claims.
The definition of “remuneration” is critical: it includes not only base salary but also variable and supplementary components, covering all elements due under law, collective agreements, or established practice.
Ban on previous salary questions
From 24 December 2025, employers in Poland cannot ask candidates about their past earnings. Both direct and indirect inquiries are prohibited. This rule aims to eliminate pay inequality and allow candidates to negotiate based on skills and market value.
Inclusive language in job ads
Job postings must be gender-neutral and non-discriminatory. Terms suggesting preferences regarding gender, age, appearance, nationality, or other traits are forbidden. Acceptable approaches include:
- Using both gender forms: “manager/manageress”, “specialist/specjalistka”,
- Adding M/F indicators: “analyst (M/F)”,
- Neutral phrases like “person for the position…” or “we are hiring for customer service”,
- Describing tasks instead of job titles.
This supports equal opportunity and reduces legal risk.
Employees’ right to pay information
Current employees will also gain the right to request:
- Their own salary details,
- Average pay levels for equivalent roles, broken down by gender,
- Criteria for determining pay, promotions, and raises, which must be objective and gender-neutral.
This strengthens employees’ ability to monitor fairness and protect their rights.
Gender pay gap reporting
Polish companies with 100+ employees must report pay gaps between men and women:
- Large firms (250+ employees) – annually,
- Medium firms (100–249 employees) – every three years.
If gaps exceed 5% without objective justification, employers must implement corrective measures. Reports will include various factors such as variable pay and employee categories. The first reports will cover 2026, making early action essential.
Penalties and compliance risks
Failure to comply may result in fines from PLN 2,000 to PLN 60,000 for issues such as lack of job evaluation or reporting. In disputes over unequal pay, the burden of proof shifts to the employer, who must demonstrate objective criteria.
How to prepare
Businesses should act now by:
- Reviewing current pay structures,
- Identifying potential disparities,
- Updating recruitment policies,
- Training HR teams,
- Revising pay grids and internal regulations,
- Informing employees about new rights.
The introduction of pay transparency on 24 December 2025 is a milestone in creating a fair and modern pay system in Poland. Companies that prepare early will avoid legal risks and strengthen their employer brand. Comprehensive audits, standardized salary bands, training, and clear communication will turn compliance into a competitive advantage.
