Labour law and HR Pay transparency is approaching, but Poland will miss the EU directive deadline
When does pay transparency come into force?
Poland will not implement the pay transparency regulations by the EU deadline of 7 June 2026. The draft act is currently at the opinion-giving and consultation stage. The most likely dates for the new regulations to enter into force are 1 January 2027 or 1 July 2027, with a six-month vacatio legis being considered.
Key takeaways
- The EU Directive requires Poland to implement pay transparency regulations by 7 June 2026.
- This deadline will not be met.
- The Polish draft act is still at the opinion-giving and consultation stage.
- The new regulations are expected to introduce, among other things, an obligation to develop a remuneration structure.
- Employees are to be granted the right to information on the principles for determining remuneration.
- Larger employers will be subject to gender pay gap reporting obligations.
- It is increasingly being indicated that the act may enter into force on 1 January 2027 or 1 July 2027.
Pay transparency is approaching, but Poland will miss the EU directive deadline
Pay transparency and the disclosure of remuneration are set to become one of the most important issues for employers in 2026. The new regulations will fundamentally change the approach to recruitment, pay policies and the reporting of pay differentials within organisations.
Although the EU directive requires Member States to implement the new rules by 7 June 2026, it is already clear that Poland will not manage to transpose the directive within this deadline.
The draft Polish act is still at the stage of opinions and public consultations.
EU Pay Transparency Directive – what will change?
The new provisions implement EU Directive 2023/970 on pay transparency and measures to combat the gender pay gap between women and men.
The purpose of the regulation is to increase the transparency of remuneration systems and to make it easier for employees to pursue claims for unequal pay.
The draft legislation is intended to introduce, in particular:
- the right of employees to obtain information on salary levels and the criteria used to determine pay,
- an obligation to create transparent remuneration structures,
- mandatory gender pay gap reporting for larger employers,
- new documentation and compliance duties on the part of companies.
For many organisations, this may mean the need to overhaul their remuneration policies, bonus schemes and recruitment processes.
What is the current status of the Polish legislation?
The Polish draft act implementing the directive has been published by the Government Legislation Centre and is currently at the stage of opinions.
The legislative process is clearly delayed, even though the implementation deadline under EU law expires on 7 June 2026.
Earlier versions of the draft provided for the new rules to enter into force as of June 2026. However, during consultations, both employers’ organisations and labour market experts indicated that businesses need a realistic amount of time to prepare for the new obligations.
As a result, there is now increasing discussion about postponing the date on which the act will start to apply.
When are the new rules likely to start applying in practice?
At this point it is difficult to indicate a final date for the entry into force of the new regulations.
In public debate, two scenarios are mentioned most frequently:
- 1 January 2027, or
- 1 July 2027.
In addition, the latest information on the draft indicates that the legislator is considering introducing a six-month vacatio legis from the date of promulgation of the act.
This means that even after the provisions are formally adopted, employers will receive additional time to adapt their organisations to the new requirements.
At the same time, companies should not assume that delays in the legislative process mean there is no need to prepare. The scale of the planned changes is so significant that implementing the new obligations may require many months of work on the part of HR departments, management boards and legal teams.
Why should companies start preparing now?
Pay transparency is not limited to disclosing salary ranges in job advertisements.
The proposed rules may require employers to:
- reorganise pay grids,
- carry out job evaluation exercises,
- establish objective criteria for remuneration and promotions,
- analyse the gender pay gap,
- implement new HR and compliance procedures,
- prepare the organisation for potential pay discrimination disputes.
In practice, the greatest challenge may prove to be not the mere disclosure of salaries, but the need to justify pay differences within the organisation based on objective and verifiable criteria.
How can we support you?
Our law firm supports employers in preparing their organisations for the upcoming pay transparency regulations, in particular through:
- audits of remuneration policies and HR procedures,
- drafting compliance procedures and internal documentation,
- support in designing and implementing transparent remuneration systems,
- training for HR teams and management,
- advisory in pay discrimination and equal pay disputes.
It is already evident that pay transparency will become one of the key areas of HR compliance in the coming years; therefore, early preparation can significantly reduce legal and organisational risks for employers.
