TGC Corporate Lawyers Legal review – June 2025

Newsletter – changes in law regulations. June 2025

Pay transparency – law signed by the President

On 18 June 2025, the President signed into law the Act of 4 June 2025. The amendment aims to increase pay transparency, strengthen equality and anti-discrimination, and better protect the privacy of job applicants.

Key changes include the obligation to disclose salaries during recruitment process. Employers will have to state the proposed salary (or range of salaries) with all components already in the recruitment advertisement, before the interview, if the employer has not advertised the post or has not provided this information in the advertisement, or before the employment relationship is established, if the employer has not advertised the post or has not provided this information in the advertisement, or before the interview. Salaries are to be determined on the basis of objective and neutral criteria, taking into account gender equality.

Moreover, it will not be possible for an employer to request from candidates the information on remuneration earned in their current or previous jobs.

The new provisions will enter into force six months after their promulgation. You can read the full text of the law here

ESG reporting for companies – government adopted deregulatory solution

On 17 June 2025, the Council of Ministers adopted a draft bill that postpones the ESG (Environmental, Social, and Governance) reporting obligation for Polish companies by two years. The decision is aimed at bringing Polish law in line with European Union regulations and enabling companies to better prepare for the new requirements. The change affects companies that were due to report in 2026 and 2027.

The new regulations are expected to enter into force on the day following their publication in the Journal of Laws. It is worth noting that work is also underway within the European Union on further changes to ESG reporting, including a potential narrowing of the list of covered entities.

You can read the draft regulations here

National e-Invoicing System (KSeF) – government says “yes” to new solutions

On 17 June, the Council of Ministers adopted a draft bill introducing the National e-Invoice System (KSeF), taking into account the demands made by entrepreneurs during consultations. The aim of the KSeF is to digitise the tax system, simplify document circulation and combat fraud. New timetable for the introduction of the e-invoicing obligation:

• from 1 February 2026 – the largest taxpayers (sales for 2024 above PLN 200 million);
• from 1 April 2026 – other entrepreneurs;
• from 1 January 2027 – the smallest taxpayers (transactions up to PLN 10,000 per month).

Moreover, until the end of 2026 the entrepreneurs will still be able to issue invoices using cash registers. The Ministry of Finance also plans to publish the technical documentation of the KSeF 2.0 API and the new FA(3) logical structure by the end of June. Open testing of the API and the release of a test version of the KSeF 2.0 Taxpayer Application are also planned. The bill will now be considered by the Sejm.

Act on the National Court Register – draft amendments

The Ministry of Justice is working on an amendment to the Act on the National Court Register. The changes aim to streamline the operation of the National Court Register (KRS), reduce bureaucracy and increase the certainty of legal transactions. Key modifications include:

• Clarification of the provisions concerning the case files of entities not entered in the register of traders but subject to compulsory entry;
• Storage of documents in an ICT system with restricted access;
• Extension of the rules for issuing copies and extracts and the obligation to anonymise data;
• Prohibition of subsequent proceedings to compel the filing of financial documents, effective from the time the reference is entered until it is removed, and deletion of the reference only after all outstanding documents have been filed;
• Prompt notification to the head of the tax office of the entry of a reference for failure to file documents;
• Obligation of the registry court to initiate liquidation proceedings one year after the entry of the mention of non-filing of financial documents. Unification of the evidentiary procedure to determine whether an entity has assets and is operating, including through access to databases (ZUS, US, CEPIK, Pledge Register, Land and Mortgage Registers);
• Streamlining the provision of information on the acquisition of real estate by foreigners;
• Obligation to indicate in declarations of foreigner status whether the acquirer of shares is a foreigner and whether the company owns real estate in Poland, facilitating control of compliance.

You can find out more about the project here

Draft Bill to amend the Act – Labour Code and the Act on the Company Social Benefits Fund

Work is underway on draft amendments to the Labour Code and the Act on the Company Social Benefits Fund. The draft aims to simplify the regulations for employers, which will reduce their burden and make settlements with employees easier. The main changes include:

• unification of the representation of employees before the employer,
• slightly extending the deadline for payment of holiday pay after termination of the employment contract,
• increasing the minimum representation of employees in matters of the Company Social Benefits Fund in companies without trade unions to two persons,
• expansion of electronic communication between the employer and employees/trade unions.

The planned deadline for the adoption of the draft by the Council of Ministers is July 2025. You can read the bill’s assumptions here

Webinar: Doing Business in Poland 2025

Watch the recording of our webinar “Doing Business in Poland 2025” and discover how to successfully establish your company, branch, or operations in one of Central and Eastern Europe’s most dynamic markets. Learn about the legal, tax, accounting, and employment essentials that every investor and entrepreneur should know before entering the Polish market.

Webinar: Pay transparency – new obligations for employers

The new Pay Transparency Directive, adopted in 2023 by the European Parliament and the Council of the EU, introduces significant new obligations for employers. The directive aims to ensure equal pay between men and women. Employers with 250 or more employees will be required to submit annual pay reports.  Smaller companies will also have to submit such reports, albeit with less frequency.

Watch the webinar recording, form which you will learn where what the principles and goals of the new EU directive are, what the gender pay gap is, and what the employers’ responsibilities in addressing it are.