Pay transparency

Pay transparency – support in implementing new regulations

The EU and Council Directive (EU) 2023/970 introduces revolutionary changes in the area of pay transparency. The new regulations are to help reduce pay inequalities and will require many employers to thoroughly restructure their pay systems. Although the deadline for implementing the Directive expired on 7 June 2026, the new regulations are still progressing through the legislative process in Poland, with their entry into force expected in early 2027. This gives organisations valuable additional time to prepare. However, it should not be seen as a reason to postpone action. Adapting pay structures can be a complex and time-consuming process that requires careful planning and a well-structured approach.

Implementing new requirements for pay transparency brings with it a number of organizational, legal, and communication challenges. Our experts will help you:

TGC Law Firm supports employers comprehensively – from analysis of current remuneration policies, through legal and HR consulting, to communication and reporting. Cooperation with us will allow you to efficiently go through the process of implementing remuneration transparency policies and avoid costly mistakes.

Pay transparency – what does it mean for employers and employees?

Pay transparency is the obligation to provide information on the pay system, pay levels, and the criteria used to determine pay. It obliges employers to provide equal pay for work of equal value, regardless of the employee's gender.

The new regulations are intended to counteract pay discrimination and promote fair remuneration.

Transparency of employee earnings

Pay transparency – employer obligations

For employers, the introduction of pay transparency requires:

• conducting job evaluations,
• development of new remuneration regulations,
• pay gap analysis and reporting,
• consulting or agreeing changes with trade unions or employee representatives.

Pay transparency

Find answers to 15 key questions asked by employers

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Pay transparency – when has it come into force?

The deadline for implementing the Directive expired on 7 June 2026. Poland is still working on the implementing legislation, which means that the full set of obligations arising from the Directive will become applicable once the national regulations enter into force.

Why is it worth starting preparations now?

• Obligations regarding transparency of remuneration rules and structures (e.g. informing candidates about pay ranges, justifying differences in pay for individual positions) will be updated from the entry into force of national provisions, which must be compliant with the Directive.
• Although the new regulations are expected to enter into force only in early 2027, employers should begin preparing now, particularly in the following areas:
  • review of remuneration systems,
  • evaluation of positions,
  • analysis of the size and causes of the pay gap,
  • preparation for reporting obligations (for companies 100+).

The process of implementing the new rules will be complex and will take time. It will be necessary to analyse existing pay structures, prepare documentation, change employment contracts, and train management and HR staff. Employers who have not previously conducted job evaluations or collected the data needed to demonstrate pay equality may face particular challenges. However, by implementing rules that counteract pay discrimination, they can increase their competitiveness on the labour market.

Pay transparency - the scope of our service

We help employers go through the entire process of adapting their remuneration structure to the requirements of the Directive in a comprehensive and safe manner.

Elements constituting the implementation of the principles arising from the Directive:

How do we work?

Stages of cooperation:

1. Needs diagnosis

We start by meeting with the client and collecting the necessary information about the remuneration structure, current internal regulations and employment contracts, and HR systems

2. Action plan

Based on the analysis, we propose a specific road map – from job evaluation, through changes in documents, consultations or agreements on changes with the social side, to communication support.

3. Implementation

We carry out the planned activities step by step, in cooperation with the HR department, legal department and the client's management board. If necessary, we also support the implementation of IT systems supporting payroll reporting.

4. Monitoring and support

We remain at your disposal even after the implementation is completed – we provide support with the first mandatory report, pay gap analyses and remedial actions.

Pay transparency - frequently asked questions (Q&A)

Do you have any questions or would like to talk about preparing your organization to implement pay transparency ?