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DARIUSZ ZIMNICKI
legal advisor
+48 605 031 290​

Pay Transparency: Poland Takes a Cautious Approach

The EU’s Pay Transparency Directive (2023/970) was designed to tackle gender pay gaps through mandatory disclosure requirements and stronger enforcement mechanisms. With President Duda signing Poland’s implementation into law on 18 June 2025, Polish employers now face new obligations—but they’re more limited than many expected.

What This Means for Your Business

Poland’s approach focuses on three immediate requirements for employers:

  1. Salary Disclosure in Job Postings: You must include either a specific salary or salary range in all job advertisements, based on objective, gender-neutral criteria. If omitted from the initial posting, this information must be provided before interviews or job offers.
  2. Inclusive Job Advertising: All job advertisements and titles must use gender- neutral, inclusive language.
  3. Recruitment Process Changes: You cannot ask job candidates about their previous or current salary during the hiring process. 

 

These requirements take effect six months after publication.

The Broader EU Framework

The original Directive envisioned more extensive transparency rights, including employee access to pay progression data and gender-based pay comparisons. It also required stronger enforcement mechanisms and dedicated monitoring bodies—elements largely absent from Poland’s current implementation.

Looking Ahead

Poland’s measured approach may evolve before the EU’s implementation deadline of 7 June 2026. For now, the changes represent manageable compliance requirements rather than fundamental shifts to pay transparency practices.

Next Steps for Members

Review your current job posting templates and recruitment processes to ensure compliance when the law takes effect.

 


Dariusz Zimnicki, Partner at ZL LEGAL Legal Advisors, contributed to this review.

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