Equal pay- delay in legislative work. What does this mean for employers?

Poland is required to implement Directive (EU) 2023/970 on pay transparency by June 7, 2026, at the latest. The purpose of this regulation is to establish the principle of equal pay for women and men for the same work or work of equal value.

The directive provides:

• the extension of information rights for candidates and employees,
• the obligation to report the pay gap
• and more restrictive standards for documenting remuneration and promotion policies.

As we reported earlier, the first part of the regulations implementing the directive, concerning the transparency of remuneration, will come into force on December 24, 2025.

Why is the legislative process being delayed?

Work on implementing the Pay Gap Directive, which was scheduled to begin this fall, has not yet been formalized. It has been suggested in the public sphere that the delays may be due to ongoing organizational changes in the government administration.

As a result, there is less and less time left to prepare national regulations on pay differences. In particular, the employment thresholds entitling an organization to submit reports and the technical requirements for publishing indicators are not yet known. This may mean that entrepreneurs will have limited time to adapt to the new obligations.

What measures are proposed for employers?

Despite the lack of detailed regulations, it is worth taking preparatory steps now. The recommended approach is to reorganize basic internal procedures related to remuneration.

Employers should start by describing job positions and defining “work of equal value” based on objective, gender-neutral criteria such as skills, effort, scope of responsibility, and working conditions. Next, it is worth analyzing remuneration policies, defining measurable criteria, and limiting discretionary elements.

The next step should be to uncover pay differences within comparable occupational groups. Such an analysis allows for the identification of areas requiring corrective action, such as for example: pay increases, a review of bonus award rules, or a review of career paths.

At the same time, it is also worth preparing the reporting process: defining data sources in payroll systems, establishing indicator definitions, determining persons responsible for monitoring and implementing quality control mechanisms.

Once the regulations come into force, greater transparency of remuneration rules and easier evidence requirements for employees may lead to an increase in the number of disputes and inspections. If the adoption of the act is further delayed, a short vacatio legis period (time necessary for the act to enter into force) can be expected, which will limit the time available to comply with the new requirements.

From the employer’s perspective, it will be important not only to fulfill reporting obligations, but also to communicate remuneration indicators both internally and externally.

Is your company ready for the upcoming changes?

Organizations that streamline their compensation systems and test their own pay gap reporting models will be better prepared to implement the new regulations.

We are monitoring the legislative process on an ongoing basis and will provide regular updates on any significant changes in the implementation of the new regulations.

If you would like to learn more about the upcoming changes or need support in employee matters, please contact our specialists from the Labor Law Department.