Last updated 2025-12-22
Quick overview
Poland currently does not impose a legal obligation on employers to calculate, report, or publicly disclose gender pay gap data. However, this position will change significantly over the next few years as Poland implements the EU Gender Pay Transparency Directive (EU) 2023/970.
At present, Polish employers are governed primarily by equal pay and anti-discrimination provisions in the Polish Labour Code. These rules already require men and women to receive equal pay for the same work or work of equal value, even though there is no formal reporting obligation.
From December 2025 onward, Poland will introduce its first statutory pay transparency requirements focused on recruitment and pay information access, with broader reporting and remedial obligations expected by 2026 as the Directive is fully implemented.
For HR, Reward, and Comp & Ben teams, Poland should be viewed as a “pre-transparency” jurisdiction: low formal reporting burden today, but a high need for preparation, data readiness, and governance alignment.
Reporting requirements
Which companies must report?
None. There is currently no obligation for any employer—regardless of size, sector, or legal form—to assess or report gender pay gap data in Poland.
What information needs to be reported?
None. Polish law does not require:
Gender pay gap calculations
Equal pay audits
Pay reporting to authorities
Public disclosure of pay data
When and where to send the data?
Not applicable. There is no reporting channel or authority for gender pay gap data under current law.
Who can see the results?
Not applicable. As no reporting is required, there are no disclosure obligations to employees, authorities, or the public.
Equal pay laws
While Poland does not mandate pay gap reporting, equal pay is already a legal requirement.
Under the Polish Labour Code:
Article 11 establishes the principle of equal treatment of employees, including equality between men and women.
Article 18 confirms the right to equal pay for equal work or work of equal value.
Equal pay covers not only base salary, but also:
Bonuses
Allowances
Benefits in cash or in kind
Any other elements linked to employment
From a legal perspective, employers must already be able to objectively justify pay differences, even though they are not required to proactively calculate gender pay gaps.
For Comp & Ben teams, this means that pay structures, job architecture, and reward decisions must withstand scrutiny if challenged.
Employee rights
At present, Polish employees do not have a statutory right to:
Request gender pay gap data
Request average pay levels by gender
Receive employer-initiated pay transparency disclosures
However, employees are protected against discrimination and may bring claims if they believe unequal pay exists.
Employee representatives (such as works councils or unions) currently have no specific rights related to gender pay gap assessment or reporting.
Risks of non-compliance
Currently, the main risk is discrimination litigation with compensation awards.
What will change by 2026
Poland is moving from no formal pay transparency regime to full EU-aligned transparency obligations.
New EU-wide rules
The EU Gender Pay Transparency Directive (2023/970) introduces far-reaching employer obligations, including:
Transparency in recruitment pay information
Employee rights to pay data
Gender pay gap reporting
Mandatory corrective action where unjustified gaps exist
How Poland is likely to apply them
Phase 1: Recruitment transparency (effective 24 December 2025)
From 24 December 2025, employers will be required to provide candidates with clear pay information during recruitment, including:
Starting salary or salary range
All variable pay components, such as bonuses and allowances
Non-cash benefits
Confirmation that pay is based on objective, gender-neutral criteria
Reference to relevant collective bargaining agreements or internal remuneration regulations
This information must be provided:
In the job advertisement, or
Before the interview, or
At the latest, before employment begins
In addition:
Employers may not ask for information about a candidate’s previous salary
Job titles and advertisements must be gender-neutral
Phase 2: Full directive implementation (expected by 2026)
Further amendments to the Polish Labour Code are expected to introduce:
Employee rights to request their individual pay level and average pay levels by gender for comparable roles
Mandatory employer response within two months
Annual employee notifications explaining these rights
Formal gender pay gap reporting obligations
Joint pay assessments with employee representatives where gaps exist
Mandatory remedial measures if gaps are unjustified
An explicit ban on pay secrecy clauses
For multinational employers, Poland will transition from a low-obligation country to one requiring robust pay governance and analytics.
FAQ
Is there currently a gender pay gap reporting obligation in Poland?
No. There is no legal requirement to calculate or report gender pay gaps today.
Can employees challenge unequal pay without a report?
Yes. Employees can bring discrimination claims based on individual pay comparisons.
When does pay transparency start to apply?
Recruitment pay transparency rules take effect on 24 December 2025.
Will Poland require public gender pay gap reporting?
Yes, this is expected as part of the full implementation of the EU Directive by 2026.
Do employers need to prepare now?
Yes. Pay structures, job evaluation frameworks, and data quality should be reviewed well in advance.
Helpful resources
Polish Labour Code (Articles 112, 183b, 183c)
EU Directive 2023/970 on Pay Transparency
Ministry of Family, Work and Social Policy – legislative updates
State Labour Inspectorate (Państwowa Inspekcja Pracy)
