On 16 December 2025, the Polish Government Legislation Centre published a draft law on strengthening the enforcement of the right to equal pay for men and women for equal work or work of equal value.

The law implements in Poland Directive (EU) 2023/970 of the European Parliament and of the Council, known as the ‘equal pay and pay transparency directive’.

The planned regulations are in line with the proposed key provisions announced in late November/ early December, and their main objective is to eliminate the gender pay gap. According to Eurostat data, in 2023, this gap in Poland was 7.8%, i.e. less than the EU average of 12.0%.

The draft law imposes new requirements on employers and broadens the scope of employees’ rights relating to pay equality and transparency. In addition, the powers of state authorities that supervise the implementation of the equal pay principle will be increased.

The key issues covered by the draft law include:

  • the obligation to conduct a job evaluation and determine categories of employees on the basis of criteria adopted by the employer,
  • transparency in determining pay levels and pay progression,
  • the obligation for employers to prepare a pay gap report (mandatory for employers with at least 100 employees) and submit it to the monitoring body (every three years for employers with 100 to 249 employees, and every year for employers with at least 250 employees),
  • the obligation for employers to take remedial action when the gender pay gap in any category of employees is at least 5% and is not justified by objective, gender-neutral criteria,
  • the obligation to conduct a joint pay assessment with the trade union or employees’ representatives if the pay gap in any category is at least 5%, the employer cannot justify it on the basis of objective criteria and does not eliminate the difference within 6 months; this obligation will apply to employers with at least 100 employees,
  • the appointment of new national bodies (a monitoring body, an equality body) and granting new powers to the National Labour Inspectorate,
  • a more precise definition of the rights of employees with respect to whom the employer has violated the rights or obligations relating to the principle of equal treatment in employment in terms of the right to equal pay, irrespective of gender,
  • penalties (a fine ranging from PLN 3,000 to PLN 50,000) for, e.g., failure to conduct a job evaluation, lack of access to information on the criteria for determining employees’ pay, failure to provide information to employees, failure to comply with reporting obligations, lack of the joint pay assessment, failure to implement remedial measures, introduction of a prohibition on disclosure of pay in contracts.

Before the new regulations come into force, we recommend that employers take steps to ensure their employee documentation meets the new requirements in Poland, i.e.:

  • Review their internal employment law regulations (remuneration rules, work rules) and contracts of employment for compliance with the provisions on equal pay and pay transparency.
  • Describe transparent pay and promotion systems and principles in their internal employment law regulations.
  • Prepare procedures and document templates needed for the employees to obtain information referred to in the provisions on equal pay and pay transparency.

According to the draft law, the planned solutions will come into force in Poland on 7 June 2026.

Should you have any questions, please do not hesitate to contact Wiewiórski Legal.

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