On May 9, 2025, the Polish parliament passed a bill introducing new provisions on pay transparency into the Labour Code. This is the first step toward implementing EU Directive 2023/970, which aims to strengthen the principle of equal pay for women and men for the same work.

The bill is currently under review in the Senate. If the legislative process proceeds without delays, the new regulations could come into force as early as December 2025. For employers, this means it’s time to start preparing – to avoid a last-minute scramble before the changes take effect.

What’s changing?

Employers will be required to provide candidates with information about the proposed remuneration – including all components, both monetary and non-monetary. This can be presented as a specific amount or a salary range, but it must be based on objective criteria and must not differ based on gender.

If a job posting does not include salary information, it must be provided before the interview or the signing of the employment contract. Moreover, the content of the job advertisement and the entire recruitment process must be gender-neutral and free from discriminatory elements.

What does this mean for companies?

This is not just a change in how recruitment is conducted, but also a need to review documents, procedures, and systems. For many companies, it’s a good opportunity to rethink their pay policies and position themselves as transparent and trustworthy employers.

It’s wise not to wait until the last minute. The earlier we prepare for the new regulations, the more likely we are to navigate the process calmly and smoothly – while also improving internal standards and communication with candidates.

Where to start?

HR and recruitment:
It’s a good idea to define salary ranges for all positions and ensure they align with the market and the company’s internal structure. Job postings should also be updated – to be clear, fair, and free from gender-specific language or implications.

We also recommend training recruiters and managers – not only regarding the new legal requirements but also in building general awareness on how to conduct job interviews ethically and lawfully.

Documentation and procedures:
Remuneration policies and collective agreements should be reviewed and updated in line with the new requirements. The draft law also includes a 14-day deadline to provide employees with information on pay levels – it’s worth having a clear procedure in place already, specifying who will handle this and how.

Systems and technology:
ATS and HRM systems should include fields for salary ranges and the ability to easily display them in job postings. It’s also useful to have a mechanism in place to quickly check whether contract terms are consistent with the offer.

And this is just the beginning

Full implementation of the EU directive is only a matter of time – starting in 2026, additional obligations will apply, including annual pay gap reporting for companies with over 100 employees, as well as audits and corrective action plans if the gap exceeds 5%. The directive also provides for the possibility of collective lawsuits against companies that fail to act.

Companies that streamline their processes now will not only avoid future stress but also gain a real advantage in recruitment and employer branding. Candidates are increasingly paying attention to transparency and fairness – and these qualities will now be legally required.

Don’t wait until December – start acting now

The changes regarding pay transparency are not just another legal obligation but also an opportunity to organise internal processes and strengthen an organisational culture based on equality and openness. At the ESG Institute, we support companies in preparing for the upcoming regulations – from reviewing pay policies to adapting procedures and conducting HR team training.

Author: Dariusz Postument (Junior ESG Specialist at ESG Institute)

ESG Institute Sp. z o. o.

info@esginstitute.eu

Rondo ONZ 1,
00-124 Warszawa

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