A pay revolution is coming! Employers, prepare for new changes and obligations.

In March, we informed our clients that the EU Pay Transparency Directive, which will come into force in 2026, imposes new obligations on employers to combat gender-based pay discrimination and promote pay transparency.

On May 9, 2025, the Sejm passed an amendment to the Labor Code, which will come into force in less than six months, on December 24, 2025. What does this mean for employers?

What is pay transparency?

Salary transparency means transparency of remuneration already at the recruitment stage. The new regulations are aimed at counteracting wage discrimination, especially on the grounds of gender, and ensuring that employees have access to information on salary ranges at the recruitment stage and during employment.

The criteria for determining remuneration must be neutral, objective, and independent of the individual characteristics of the employee, in particular gender.

New obligations for employers in Poland

Employers will be required, in particular, to ensure that job offers and job titles are gender-neutral and that the recruitment process is free from any discrimination.

From December 24, 2025, employers will have to specify in job advertisements the amount of remuneration, specified in detail, with all its components (bonuses, allowances, benefits). The employer will be able to specify the initial salary or the so-called salary range.

It will not be possible to ask an employee about their salary at previous places of employment. The aim of this solution is to create a level playing field in the recruitment process, regardless of the candidate’s professional history and previous rates.

What is more, an employer covered by a collective labor agreement or one who has remuneration regulations in place will be required to inform the employee about the relevant remuneration rules already at the recruitment stage!

When should information about remuneration be provided to the candidate?

The employer will have to provide the above information to the job candidate already in the job advertisement, before the interview, if the job advertisement did not contain information about remuneration, or before signing the employment contract, if such information was not provided earlier in the job advertisement or before the interview.

Employees’ right to request disclosure of remuneration

During their employment, employees will be able to request information about the remuneration of their colleagues from their employer.

On this basis, they will be able to check whether the employer is discriminating in employment in similar or the same positions. Upon written request from an employee, the employer will have to respond within 14 days of the request being made.

This means that remuneration will be completely transparent, and employers will not be able to prohibit employees from discussing their salaries.

Proposed measures for employers

The entry into force of the new regulations entails numerous obligations for employers, which it is worth preparing for today.

Firstly, employers should update their existing remuneration and bonus regulations and prepare a remuneration policy and objective salary ranges. It is worth ensuring that the remuneration policy includes information on the amount and components of remuneration according to positions in the company.

We also recommend standardizing job titles and job descriptions for specific positions, as well as checking whether employees in the same or equivalent positions are paid the same.

We recommend preparing HR and payroll departments for their new responsibilities, as they will most often be responsible for preparing employment-related documents, job advertisements, and calculating employee remuneration.

Penalties for employers for non-compliance with the new regulations

For failure to include salary ranges/salary amounts in job advertisements, hiring an employee for a lower salary than that specified in the job advertisement, or failing to provide the employee with information on salary amounts, employers may be subject to a fine of PLN 1,000 to PLN 30,000.

Do you need support in implementing the new employment rules?

The new regulations will come into force in six months. They are intended to improve the transparency of the labor market and reduce unequal treatment in employment. These changes will be a challenge for employers, so if you need assistance in updating your remuneration rules in line with the new regulations, please contact our specialists from the Labor Law department: [email protected]