The upcoming changes to regulations on equal treatment of women and men in employment are not an evolution, but a genuine revolution in how remuneration is managed in Poland. The new legislation, set to enter into force on 7 June 2026, imposes a range of obligations on employers that will fundamentally transform pay policy rules. The time available for preparation is very limited, while the stakes are high—both financially and in terms of corporate reputation.
Pay Transparency Act – The End of Pay Secrecy
Transparency is the cornerstone of the new regulations. The Act introduces a prohibition on including pay confidentiality clauses in employment contracts. Employees will gain the right to access information not only about their own remuneration, but also about average earnings broken down by gender within the same job category.
Moreover, already at the recruitment stage, employers will be required to inform candidates about the expected salary or its range, and job advertisements must use gender-neutral job titles.
Job Evaluation as a Challenge for Every Employer in Poland
Every employer will be required to conduct a job evaluation for individual positions.
This process must be based on objective and gender-neutral criteria, such as:
- required skills (including soft skills),
- effort and scope of responsibility,
- working conditions,
- and, where applicable, other criteria and sub-criteria defined by the employer, reflecting the specific nature of a given role.
In addition, companies employing at least 100 employees will be subject to an obligation to regularly report on the gender pay gap. If the report reveals a pay disparity exceeding 5% that cannot be justified by objective factors, the employer will be required to take corrective measures within six months.
Small Employer, Big Challenge – Why Pay Transparency May Pose a Risk for SMEs
Although certain reporting obligations depend on the number of employees, the prohibition of confidentiality clauses and the requirement to ensure equal pay for work of equal value apply to every business, regardless of its size.
This is where the greatest risk for the SME sector arises. Smaller employers often lack extensive HR departments or in-house legal teams capable of independently developing complex job evaluation systems or procedures for providing pay-related information. At the same time, the legislation does not provide for any preferential treatment.
Non-compliance with the regulations may result in financial penalties ranging from PLN 3,000 to as much as PLN 50,000, irrespective of the size of the company.
Pay Transparency in Poland-Based Companies – Why Expert Support Matters
Implementing new procedures independently at the last minute carries a significant risk of errors. In the event of a legal dispute, the burden of proof will rest with the employer to demonstrate that no pay discrimination has occurred, particularly if transparency obligations have previously been breached.
In this context, the role of external advisory firms with the necessary know-how becomes crucial.
Engaging expert support enables companies to:
- conduct a professional pay audit and identify potential irregularities before the regulations come into force,
- properly develop salary structures and employee classifications based on neutral criteria,
- safeguard the organisation against compensation claims, which may amount to at least the equivalent of the statutory minimum wage.
When Will Pay Transparency Take Effect? Now is the Time to Act
The first reports for the largest companies (employing over 150 employees) will have to be submitted by 7 June 2027. However, preparing remuneration structures, aligning them, and training management staff are processes that take months.
We encourage all employers to begin work on new procedures without delay. Early implementation of transparency principles not only helps avoid significant financial penalties, but above all supports the development of a strong employer brand built on fairness and professionalism.
Do not wait until June 2026 – the future of your finances and employee relations depends on the decisions you make today. Contact us if you need expert support.