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ALERT / OCTOBER 14, 2025
Poland to implement pre-employment requirements of the EU Pay Transparency Directive
4 MIN READ
Poland has partially transposed the European Union Pay Transparency Directive by introducing pre-employment requirements. These new requirements include mandatory disclosure of remuneration information to job applicants, gender-neutral job advertisements and titles, non-discriminatory recruitment processes, and a ban on requiring job applicants to provide their salary history. The changes will take effect from 24 December 2025.
Background
The European Union Pay Transparency Directive (Directive (EU) 2023/970, the “EU Directive”) entered into force on 6 June 2023 and requires each EU member state to transpose its provisions into their national law by 7 June 2026. The EU Directive sets minimum standards to strengthen pay transparency, promote equal pay for equal work, and impose gender pay gap reporting obligations on employers. While Member States must meet these minimum standards, they are also free to go beyond them, meaning national approaches to pay transparency may vary across the EU. (See Lockton article here (opens a new window) for more details on the EU Directive and creating a roadmap for compliance.)
Poland has begun transposing the EU Directive’s provisions through the Act of 4 June 2025 (the “Act”), which was published in the Journal of Laws on 23 June 2025. The Act introduces new pre-employment requirements through amendments to the Labor Code with effect from 24 December 2025.
Since the Act only addresses pre-employment requirements under the EU Directive, further legislative measures will be required for Poland to fully transpose the EU Directive by the June 2026 deadline.
Key details
Mandatory disclosure of remuneration information to job applicants
Job applicants will have the right to receive information from the employer on:
The initial remuneration or range of remuneration, which must be based on objective and neutral criteria, especially regarding gender.
If an employer is covered by a collective bargaining agreement or has remuneration regulations in force, the relevant provisions of such agreement or regulations.
Such information must be provided to the job applicant in advance, either in paper or electronic form, to enable the applicant to familiarize themselves with the information and ensure informed and transparent negotiations.
This can be done in the job advertisement, before the interview, or before entering into an employment relationship.
This provision varies from the standard set under the EU Directive that employers must disclose the pay or pay range either in the job advertisement or prior to the interview. The EU Directive does not provide that the disclosure may be done at a later stage in the recruitment process (for example, before entering into an employment relationship).
Gender-neutral job advertisements and titles
Employers will be required to ensure that job advertisements and job titles are gender-neutral. This is in line with the minimum standard under the EU Directive.
The Act does not define “gender-neutral” or set out specific approaches as to how to ensure job advertisements and titles are gender-neutral. In practice, this means that language used in job advertisements and titles should not imply a preference for a specific gender or exclude a specific gender.
Non-discriminatory recruitment processes
Employers will be required to ensure that the recruitment process is conducted in a non-discriminatory manner. This is in line with the minimum standard under the EU Directive.
The Act does not define “non-discriminatory” or set out specific approaches as to how to ensure the recruitment process is conducted in a non-discriminatory manner. However, in practice, conducting the recruitment process in a non-discriminatory manner would mean applying objective and gender-neutral criteria at every stage, without treating job applicants differently based on gender or using practices that unfairly disadvantage one gender.
Ban on requiring job applicants to provide their salary history
Under the Labor Code, employers are currently allowed to require job applicants to provide their previous employment history.
From 24 December 2025, employers will still be allowed to require job applicants to provide their previous employment history. However, they must exclude information on remuneration in current and previous employment relationships.
Employer action: ACT
Employers should review and prepare to update their recruiting and HR policies, practices and procedures, as needed, to comply with the changes from 24 December 2025.
If there are any additional legislative proposals to further transpose the EU Directive, the Lockton Global People Solutions Compliance Practice will publish an update accordingly.
Further Information
