EU Pay Transparency Directive Status Poland: Draft Published, Deadline Missed
Poland's government legislative center published an updated, more complete draft transposition bill on 4 May 2026, building on an earlier consultation draft from December 2025 and covering gender pay gap reporting, job evaluation, information access, and joint pay assessment obligations that were not part of the December 2025 amendments. As of the research date this fuller bill had not yet been referred to the Sejm (Polish parliament) for formal legislative consideration, and it includes a built-in delay of six months between final publication and entry into force, meaning full compliance is unlikely before early 2027 at the earliest even if the bill proceeds smoothly. Because the bill has not been enacted, all thresholds, penalty amounts and reporting dates described below reflect the current draft and could still change; commentary from legal trackers flags a genuine risk that Poland's full transposition slips further given ongoing legislative and institutional review. The pre-employment obligations that took effect in December 2025, by contrast, are already binding law today.
What is Pay Transparency, and who does it apply to?
The EU Pay Transparency Directive (Directive (EU) 2023/970) is a binding EU law requiring pay equity for equal work between women and men. It introduces mandatory rules around salary disclosure, pay gap reporting, and worker rights.
Poland's Labour Code already guarantees equal pay for equal work, and amendments effective 24 December 2025 introduced pre-employment pay transparency duties such as salary ranges in job postings, ahead of the broader EU Directive. Poland missed the 7 June 2026 EU-wide transposition deadline for the remaining obligations, including gender pay gap reporting, and a fuller standalone draft law was still moving through the legislative process as of the research date, with a credible risk of further delay.
All Polish employers, regardless of size, are already covered by the job-ad salary range and salary history ban rules in force since December 2025; the proposed gender pay gap reporting duties in the pending draft would apply from 100 employees upward, with annual reporting proposed for 250 or more employees and reporting every three years for 100 to 249 employees, though these thresholds remain subject to change until the bill is enacted.
What employers must do in Poland
All employers, regardless of size (already in force since 24 Dec 2025)
- Include salary ranges in job postings or disclose them before interview
- Do not ask job applicants about their salary history
- Use gender-neutral job titles and job descriptions
Employers with 100 to 149 employees (proposed, not yet in force)
- Prepare gender pay gap reports every three years once the fuller law takes effect, proposed to start around 2031
Employers with 150 to 249 employees (proposed, not yet in force)
- Prepare gender pay gap reports every three years, proposed to start around 2027
Employers with 250 or more employees (proposed, not yet in force)
- Prepare annual gender pay gap reports covering mean and median gaps, bonus pay gaps, and pay quartile distribution, proposed to start around 2027
- Conduct a joint pay assessment and job evaluation where an unexplained gap of 5% or more is found
Key deadlines
Penalties for non-compliance in Poland
The pre-employment transparency rules in force since December 2025 fall under general Labour Code sanctions; the pending fuller draft law separately proposes fines ranging from roughly 2,000 to 60,000 Polish zloty for failures such as job evaluation, information access, reporting, joint pay assessment, or corrective measures, though these amounts are not yet finalized.
The State Labour Inspectorate already enforces the existing Labour Code pay transparency provisions and is expected to serve as Poland's monitoring body for gender pay gap reporting once the fuller law is enacted.
How TalentUp can help you with Pay Transparency Compliance
Below you can see a preview of our platform, where we help you stay compliant with Pay Transparency by spotting pay inconsistencies and structural risks in your compensation strategy, analysing data from your company.
Book a demo| Name | Level | Location | Salary | Labels | Actions |
|---|---|---|---|---|---|
|
John Doe
Software Developer
|
Mid
|
Warsaw
Poland
|
32500 EUR
Above market
|
Unbalanced
|
|
|
Jane Smith
Project Manager
|
Senior
|
Warsaw
Poland
|
45000 EUR
Above market
|
In Market
|
|
|
Michael Brown
Data Analyst
|
Mid
|
Krakow
Poland
|
39000 EUR
Above market
|
In Market
|
|
|
Emily Johnson
QA Engineer
|
Mid
|
Krakow
Poland
|
36000 EUR
Above market
|
In Market
|
|
|
Robert Wilson
HR Manager
|
Senior
|
Wroclaw
Poland
|
50000 EUR
Above market
|
Above Market
|
|
|
Sarah Davis
Marketing Specialist
|
Junior
|
Wroclaw
Poland
|
34000 EUR
In market
|
In Market
|
MEAN PAY
39.4K EUR
MEDIAN PAY
37.5K EUR
MEAN FEMALE PAY
38.3K EUR
MEDIAN FEMALE PAY
36K EUR
MEAN MALE PAY
40.5K EUR
MEDIAN MALE PAY
39K EUR
Gender gap
Variable pay by gender
General gender pay gap
Pay gap insights
Add employee data to see pay gap insights
Tenure distribution
Pay gap per level (quartiles)
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Frequently asked questions about pay transparency in Poland
Yes, partially. Since 24 December 2025, Polish employers must include salary ranges in job postings and are banned from asking about salary history, though the fuller gender pay gap reporting regime is still only a draft.