Poland: Pay Equity Landscape and EU Directive Transposition Updates

In late 2024 and early 2025, Poland considered legislation that would have partially transposed the EU Pay Transparency Directive into law. This article gives an overview of the pay equity landscape in Poland as well as more information about the proposed legislation.

Pay equity in Poland

As of 2022, the average unadjusted gender pay gap across all EU nations was 12.7%—that is, women were paid 12.7% less than men. Some of the highest pay gap measurements come from Eastern European countries, with Estonia, Slovakia, Czechia, Hungary, and Latvia all coming in at over 17%.

Compared to some of its neighboring countries, Poland is a standout, with a gender pay gap of 7.8%. It also has one of the most even gender balances at the management level, with 43% of all managers being women. This was, at the time of data collection, the second highest proportion in the EU.

Poland has overarching equal pay laws that protect against gender-based pay discrimination, as well as some equal pay regulations that are specific to certain fields (like banking).

The country currently has no pay transparency legislation or gender pay gap reporting requirements. However, it has taken some steps to promote pay equity. In 2018, the government developed a software application to help employers estimate their adjusted gender pay gap (accounting for factors like education and age). Employers have been encouraged to use it to develop non-discriminatory pay policies and structures.

Transposition updates: Draft amendments voted down

In December 2024, a group of members of parliament proposed amendments to Poland’s Labor Code. These amendments would have enacted a partial transposition of the Directive. Specifically, they would have:

• Required employers to post minimum and maximum pay in the job posting. Like draft legislation currently circulating in Ireland, this provision would go beyond the Directive’s requirements (which say that remuneration information must be provided before the interview) to say that it must be in the job ad itself.
• Stipulated that employees have the right to request a comparison between their pay and the pay of other comparable employees. The employer would be required to provide this within 14 days. Like the previous provision, this one would actually go beyond the requirements of the Directive (which states that employers should provide this information within two months).
• Required employers to, at the employee’s request, provide information on the objective, gender-neutral criteria used to determine pay. In addition, employers with 50+ employees would need to be able to provide information on how pay levels are determined.
• Protected employees’ right to talk about their pay with other employees
• Set fines (1,000-30,000 zloty) for failing to comply with the above. Such fines are not a requirement of the Directive.

This proposed legislation was not a total transposition, as it did not address the following Directive requirements:

• Gender pay gap reporting and the specific metrics required under the Directive
• Pay assessment and gender action plan requirements for employers with a pay gap of 5% or more that they cannot close within six months

This legislation did not move forward. Poland’s lower house of parliament (Sejm) voted against these proposed amendments on February 6, 2025. The draft bill is currently with the Extraordinary Committee for Amendments to Codifications (Komisja Nadzwyczajna do spraw zmian w kodyfikacjach), which will review and make changes. So despite not moving forward, we may see elements of this legislation reappear as Poland continues to figure out how they want to adopt and adapt the EU Directive.

Further support with PayAnalytics by beqom

This is a good time for Polish employers to start preparing for implementation of the EU Directive. Companies will need to be able to make sure that they have well-defined criteria to determine pay, that they are clear on what salary ranges they will offer for each position, and that they are ready to measure and close any gender pay gaps.

Here’s how PayAnanlytics by beqom can help:

Pay equity analysis: Our software solution is ideal for any employers in the EU that want to be ahead of the curve in closing their pay gaps. User-friendly and designed by data scientists, PayAnalytics by beqom identifies your organization’s demographic pay gaps and proposes cost-effective targeted raises to close them.

Compensation assistant: If your organization has narrowed or closed its pay gap, how do you make sure that it never opens again? This requires careful calculation of each pay decision involved in hiring and promotion, which could be a time-consuming and labor-intensive process. Our compensation assistant tool automates this process, giving you ongoing support to show what any potential pay or promotion decision would do to your pay gaps.