Poland Pay Transparency Law: EUPTD Transposition Status
Local term: jawność wynagrodzeń
As of 28 September 2026: Poland has partly transposed the Directive. Recruitment pay transparency has applied since 24 December 2025. A revised draft act for the remaining obligations, including reporting, was published on 4 May 2026 and would apply six months after publication.
Status snapshot
| Status | Draft published (partly in force) |
|---|---|
| National instrument | Recruitment pay transparency (Labour Code amendments) in force since 24 December 2025. Draft act implementing the remaining provisions published 4 May 2026. |
| Official source | Government Legislation Centre (legislacja.gov.pl) |
Pay gap reporting required before the Directive
No national gender pay gap reporting obligation before the Directive.
When Directive (Article 9) pay gap reporting starts
Article 9 reporting covers seven indicators: the mean and median gender pay gap, the mean and median gap in variable pay, the proportion of women and men receiving variable pay, the proportion of women and men in each pay quartile, and the gender pay gap by category of workers.
Not yet legislated.
Things to work on now
- Priority for Poland. Recruitment rules already apply: check Polish adverts and recruitment processes give pay or a range and use gender-neutral job titles.
- Map the draft. Compare the published draft with your current practice and note where it goes further than the Directive.
- Job architecture. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4). This is needed whatever the final text says.
- Pay ranges. Agree pay ranges for roles so you are ready for pre-employment disclosure (Article 5).
- Shadow reporting. Run a trial gender pay gap calculation on 2026 data using the Directive's Article 9 indicators, including by category of workers.
- Remediation budget. Model the cost of closing unexplained gaps of 5% or more, which would trigger a joint pay assessment (Article 10).
Legislative timeline
- 24 December 2025Recruitment pay transparency in force
- 29 April 2026Revised draft act dated
- 4 May 2026Revised draft published
Frequently asked questions
Has Poland transposed the EU Pay Transparency Directive?
Poland has partly transposed the Directive. Recruitment pay transparency has applied since 24 December 2025. A revised draft act for the remaining obligations, including reporting, was published on 4 May 2026 and would apply six months after publication.
When does gender pay gap reporting start in Poland?
Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Poland.
What should employers in Poland do now?
Recruitment rules already apply: check Polish adverts and recruitment processes give pay or a range and use gender-neutral job titles. Compare the published draft with your current practice and note where it goes further than the Directive. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4). This is needed whatever the final text says.