Pay transparency in recruitment coming to Poland in 2025

Poland's Act of June 4, 2025 amended the Labor Code and partially transposed EU Directive 2023/970 on pay transparency, focusing specifically on the directive's pre-employment requirements. Overall, the directive aims to ensure equal pay for equal work or work of equal value between men and women by giving employees extensive new rights to information about their own pay and the pay of their male and female peers. The act will come into force on December 23, 2025, six months following its publication. The deadline for all EU member states to transpose the directive's provisions into local law is June 7, 2026.

What are the key details?

The act's key points impacting employers' recruitment activities include:

• Employers must inform all job candidates about the remuneration they would receive if hired, including the salary rate or range for the job. Under the Labor Code, "remuneration" encompasses all reward elements, both in cash and in kind, for both regular and exceptional work (such as overtime). In the event the employer is covered by a collective bargaining agreement, its provisions related to remuneration must also be communicated to job candidates
• This information can either be included in job advertisements, or provided prior to any interviews or provided before the start of employment (if, for example the candidate wasn't interviewed). The intent is to ensure the candidate is able to have informed and transparent negotiations with the prospective employer. In addition, employers must ensure that the contents of job advertisements (both titles and role descriptions) are gender-neutral in nature
• The determination of remuneration packages must be based on objective criteria irrespective of gender. Employers may not ask candidates to disclose their current or previous pay levels or remuneration composition

What are the implications for employers in Poland?

Employers should review their recruiting processes and documentation to ensure they will be compliant with the new recruitment requirements when they come into force, and monitor developments concerning future transposition of other provisions of the directive. According to Eurostat, in 2023, the Polish gender pay gap was 7.8% (versus the EU average of 12.0%).

Contact

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Krzysztof Gugała

email Email phone +48 501 130 007

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