Poland's Pre-Employment Pay Transparency Rules — Phase 1 of the EU Pay Transparency Directive

Poland began transposing the EU Pay Transparency Directive (2023/970/EU) in two phases. The first phase, arising from the Act of 4 June 2025, took effect on 24 December 2025 and applies to recruitment: employers must disclose a starting salary or salary range in job advertisements, or at the latest before an interview or contract offer, based on objective and gender-neutral criteria. Job titles must be gender-neutral, and employers may no longer ask candidates about their current or previous pay.
A second, broader phase was published as a draft bill on 16 December 2025 and is intended to take effect on 7 June 2026, the Directive's EU-wide transposition deadline. It would require job evaluations for equal-value work, annual gender pay-gap reporting for larger employers, and a mandatory gender action plan for any employer with an unexplained gap of 5% or more that persists after six months. Non-compliance would carry fines of up to PLN 50,000.
As of September 2026, only the recruitment-stage rules are in force; the wage-reporting and job-evaluation obligations remain in the legislative process, so Poland's full transposition — and its ultimate effect on the gender pay gap — cannot yet be evaluated.

Read the full analysis: https://ogletree.com/insights-resources/blog-posts/poland-pay-transparency-measures-employers-must-implement-by-24-december-2025/