Pay transparency in Poland – a new draft law implementing the Directive

On April 29, 2026, a new version of the draft law implementing the EU Pay Transparency Directive was published. Compared to the draft from December 12, 2025, the provisions have been clarified and amended on those issues that raised the most serious concerns. The expected adoption of this law means employers need to urgently prepare their organizations for the upcoming changes.

The first version of the implementing act was met with widespread criticism, so this year’s draft addresses many demands from employers and the social community. A significant portion of the changes consist of clarifying the principles, concepts, and employers’ obligations regarding job evaluation. In addition to the draft act, a draft regulation has been published containing detailed salary reporting, which is intended to ensure reliable and consistent data.
The act implementing the Directive will not enter into force on the date specified in the Directive (June 7 of this year), but six months after its publication. This should not be interpreted as a signal to postpone the changes. On the contrary, given the low level of awareness of the changes awaiting all employers, the vacatio legis should be treated as an opportunity to take immediate action during this additional period to streamline remuneration structures. This will not only help achieve the directive’s objectives but also avoid misunderstandings and conflicts regarding equal pay.

What is new in the latest version of the bill (May 2026)?

Compared to the previous version of the project, the following has been clarified:

definition of “salary level”,

principles of job evaluation,

procedure for agreeing on evaluation criteria with trade unions,

definition of “salary structure”,

how to calculate the pay gap and report data

What has been added or clarified in the new version of the act?

Area	2025 version	2026 version
Criteria for evaluating work	There were four mandatory criteria (skills, effort, responsibility, working conditions).	A clearer distinction is made between mandatory and optional criteria.
Salary structure	Obligation to have it, but without a detailed statutory definition.	A statutory definition of “remuneration structure” has been added.
Uniformity of job evaluation	It resulted indirectly from the draft.	The obligation to apply uniform criteria to all positions and types of work was clearly indicated.
Trade unions	Less detailed regulations regarding union participation.	A procedure has been added in the event of a disagreement between the employer and trade unions when establishing job evaluation criteria.
The right to disclose one’s salary	Based mainly on the requirements of the directive.	The employee’s right to disclose information about his or her own remuneration was expressly confirmed.
Equality Authority	The competencies were described, but they raised questions of interpretation.	The competence of the body responsible for enforcing the regulations has been clarified.
Pay Gap Reporting	General reporting principles.	The method of counting the number of employees and other reporting parameters have been detailed.

What does this mean for employers?

The new version does not change the direction of the reform but significantly limits the scope for different interpretations. Employers receive more detailed guidance on:

building remuneration systems,

job evaluation,

cooperation with trade unions,

pay gap reporting,

sharing information with employees.

Higher penalties for lack of transparency – what?

The 2026 draft changes the sanctions system:

the maximum fine was increased to PLN 60,000,

the lower threshold was lowered to PLN 2,000.

Joint salary assessment procedure – when?

The obligation to carry out a joint remuneration assessment will arise when all the following conditions are met:

employing at least 100 employees,

identified pay gap ≥ 5%,

no objective justification for the difference,

failure to close the pay gap within the statutory deadline (by 30 September of the reporting year).

The assessment will be carried out in cooperation with trade unions or employee representatives.

As part of the joint pay review, there will also be an obligation to analyse pay increases for employees returning from maternity and parental leave. Employers will be required to verify whether these employees received the same pay increases as those in the same positions during their absence.

A greater role for trade unions and the National Labour Inspectorate

The project introduces:

30-day deadline for agreeing on remuneration criteria,

obligation to inform the National Labour Inspectorate (PIP) about the lack of agreement with the social side.

This significantly formalizes social dialogue in the area of remuneration.

How should employers prepare for the changes?

We recommend taking the following steps:

1. Salary Audit
Analyse salary setting methods and any potential salary gap.

2. Preparing data for reporting
Verify HR and payroll systems for AWU (annual work unit) calculation.

3. Procedures for cooperation with the social side
Develop rules and a schedule for consultations with unions or employee representatives.

4. Sanctions risk management
Prepare procedures for responding to inspections and inquiries from the supervisory authority.

Summary

The new draft bill on pay transparency strengthens mechanisms for monitoring and enforcing equal pay. For employers, this means the need to quickly prepare their organizations, both socially and procedurally. Appropriate actions taken early will reduce the risk of sanctions and facilitate compliance with the new requirements.

Pay transparency