Labour law and HR Pay transparency in Poland – one month after publication
It’s been a month since the pay transparency amendment to the Polish Labour Code was published in the Journal of Laws. The new provisions will come into force on December 24, 2025 — a date that’s closer than it seems.
From the perspective of employers, the time to prepare for change starts now. And it is worth using it wisely.
Key changes – what’s new?
• Mandatory pay ranges in job ads – employers will be required to include the proposed salary or salary range in job postings.
• Ban on asking about past earnings – during recruitment, employers will no longer be allowed to ask candidates about their previous salary.
• Obligation to inform future employees about remuneration rules – companies must ensure transparency of procedures and criteria.
• Neutrality of job advertisements – it will become unacceptable to formulate job offers in a way that suggests the company's preferences regarding age, pay, or other criteria for candidates.
• Upcoming obligation to develop a remuneration structure – this is still ahead of us, but it is worth being aware today that the EU directive requires much more.
Just the first step
It’s essential to emphasise that the published amendment does not yet fully implement EU Directive 2023/970 on pay transparency. This is only the first stage – the legislator will implement further changes, including the obligation to develop a remuneration structure, report on the pay gap, and extend the rights of employees and their representatives.
Poland must fully implement the directive by June 2026. But it is not worth waiting until the last minute.
What should employers do now?
• Analyze job advertisement content.
• Update recruitment procedures.
• Organize remuneration and promotion rules.
• Identify areas of potential discrimination.
• Prepare for the next stages of the directive's implementation.
How can we help?
For months, we have been supporting our clients in preparing for the implementation of EU regulations on pay transparency. We offer:
• audit of HR documentation and recruitment practices;
• assistance in developing remuneration rules and transparency policies;
• communication support and training for HR teams and managers.
