EU Pay Transparency: New rules in Poland effective from December 24, 2025

Why should I read this?

Poland is implementing changes to its labour law to transpose an initial part of the EU Pay Transparency Directive (Directive) through its Act (Law of 4 June 2025) amending the Labour Code (Act).

From December 24, 2025, employers operating in Poland, regardless of size, must comply with new obligations around pay transparency in recruitment practices. Non-compliance can result in a claim for damages by impacted workers, as well as potential reputational risk.

This briefing outlines the key obligations under the Act, its anticipated impact and what is coming next in Poland in relation to its implementation of the remainder of the Directive.

“Pay transparency in recruitment is now the law, not a choice. Proactive compliance reduces legal risk, safeguards an organization’s brand, and ensures smooth hiring under Poland’s new requirements.” Pawel Lasota, Senior Associate

What do I need to know?

Under the current provisions of Poland’s Labour Code, only general non-discrimination rules apply to the recruitment process and there is no obligation to disclose details of pay during recruitment. Further, the current provisions do not include any express prohibition on asking about a candidate’s current remuneration.

This position is set to change in Poland from December 24, 2025. In particular:

• Information to be provided to job applicants: Prospective employers will now be legally obliged to disclose the initial remuneration or remuneration range for the position applied for, together with the provisions of any collective bargaining agreement or remuneration regulations concerning remuneration. This is a significant shift towards transparency in recruitment practices. By requiring disclosure of all components of remuneration, whether cash or in kind, candidates gain a clearer picture of the total reward package on offer. This includes not only base salary but also any applicable bonuses, commissions, overtime pay, allowances, benefits, and pension contributions
• Timing of information: The Act requires pay information be shared at one of three stages: in the job advertisement, before the interview, or before entering into the employment relationship. This flexibility allows employers to choose the most practical point of disclosure, but the underlying principle is clear: candidates should not be left guessing about pay until the last minute and have time to familiarize themselves with it to ensure informed and transparent negotiations
• The form of the information to be provided: The information must be provided to applicants in paper or electronic format. Where the information is verbally communicated, such communication must therefore be followed up in writing to ensure compliance. This requirement creates an auditable trail, which is crucial for demonstrating adherence to the law and avoiding disputes
• Gender-neural job advertisements: Job titles and advertisements must be gender-neutral and recruitment processes conducted in a non-discriminatory manner. This aligns with broader EU and global trends promoting equality and diversity in the workplace. Employers should review their job descriptions and advertising templates to eliminate gendered language and ensure inclusivity
• Prohibition on asking about a candidate’s current remuneration: Employers cannot ask candidates about current or previous pay. This is a key measure to combat pay discrimination and prevent perpetuation of historical pay gaps. However, employers may still ask about salary expectations, which allows for negotiation without relying on past earnings. Organizations should update their recruitment practices, including training hiring managers, to avoid prohibited questions

Anticipated impact

The new Act does not provide for any fines or criminal offence for non-compliance with the recruitment requirements. However, a failure to comply may result in a claim for damages under the Labour Code.

Whilst the risk of a claim is low, potential compensation is calculated from a minimum of the monthly minimum wage (PLN 4,666 (1,103 EUR) gross in 2025, rising to PLN 4,806 (1,136 EUR) gross in 2026), with no statutory maximum cap.

The risk of potential financial penalties for non-compliance with the Act may be modest if awarded at the minimum level, however the reputational damage can be much greater. Failure to disclose pay or maintain gender-neutral practices can deter top talent and attract negative publicity—risks that outweigh the cost of fines.

What is coming next?

The Act (Law of 4 June 2025) amending the Labour Code transposes just one discrete aspect of the Directive, relating to recruitment. The remainder of the Directive must be transposed by no later than June 7, 2026.

On November 25, 2025 a summary was published by the Polish government of the key terms to be included in the new legislation to implement the remainder of the EU Pay Transparency Directive. Based on this summary only, it currently appears that the new legislation will simply replicate rather than go beyond the requirements of the Directive. No date has yet been given as to when the new draft law will be published for consultation.

How we can help

Our pay transparency interactive tracker has been designed to help employers navigate the requirements of the EU Pay transparency Directive and track developments, as well as providing access to essential FAQs, timelines and briefings.

Our extensive global footprint and our established equal pay practice means that we are well placed to support global employers in getting ready for pay transparency compliance, wherever they have a presence. Our teams of lawyers are not only experts in the complexities of different laws, but also in the management of projects spanning jurisdictions and driving those projects to maximize the strategic aims and benefits. Some of our recent work in this area includes:

• reviewing pay architecture through the lens of work of equal value to advise on compliance
• conducting pay gap analyses against current practices
• advising on local legal developments
• developing action plans
• advising on how to structure the project to maximize privilege and the confidentiality of sensitive pay data and potential gaps
• drafting local and EU consistent templates and processes
• delivering training

Please contact us should you require advice or assistance in relation to pay transparency compliance, or access to the pay transparency interactive tracker.