Labour Law and HR Revolution in remuneration: Pay Transparency Directive changes the rules of the game
When will the Directive become effective in Poland?
The Pay Transparency Directive came into force in June 2023. Member states, including Poland, have until June 7, 2026 to implement it into national law.
For Polish employers, this means that over the next two years they need to take steps to adapt their remuneration policies to the new requirements. Early preparations will avoid chaos and mistakes, and can become a competitive advantage in the labor market. Why? We explain below.
Who does the Directive cover?
The Directive applies to all employees and employers, regardless of the size of the company or the industry in which they operate.
The Directive will cover private and public sector employers.
Speaking of employees, on the grounds of the Directive, we also mean job applicants. And this is an important aspect, because obligations also await employers in relation to this group.
For employers, the above means specific obligations they must fulfill, such as the implementation of a remuneration structure, which from 2026 will be a mandatory document for every organization, regardless of the number of people in it.
Basic obligations of employers
The Pay Transparency Directive imposes a number of obligations on employers, the first and most important of which applies to everyone, regardless of the size of the company.
This is because every employer must implement a remuneration structure that provides:
• equal pay for equal work or
• work of equal value.
This implies the need for transparent rules that eliminate wage discrimination and ensure that all employees performing comparable tasks are paid fairly.
For larger companies with more than 100 employees, the Directive introduces additional obligations, such as regular reporting of data on the wage gap between employees in similar positions.
Toward job candidates comes the obligation to inform about the starting salary or its range for a given position, and this before the interview. This is to ensure transparency already at the recruitment stage.
Why start taking action now?
Implementation of the Directive's requirements is a time-consuming process. Preparing the remuneration structure requires a detailed analysis of the current remuneration rules, identifying gaps or irregularities and developing new pay mechanisms. Each step requires time and the involvement of many people.
This is no longer the time to ask “whether to implement pay transparency”, but “when to do it”
And the answer to this question is crucial.
Companies that start the implementation process earlier will gain time to prepare for the changes calmly and effectively – analyze existing pay structures, eliminate possible inequalities and develop clear remuneration rules.
This approach not only avoids costly mistakes, but also builds a competitive advantage in the labor market, strengthening the organization's image as a modern and responsible employer.
Our support for employers
As a law firm for more than 30 years, we have been supporting employers in the field of labor law, including creating pay policies and building a strong corporate culture. With our experience, we help companies adapt to new regulations while ensuring proper communication with employees so that the change process goes smoothly and fosters trust within the organization.
We will regularly explore the topic of the Directive on our blog, and for more practical information, please visit our training series Employer Pro: Organizational culture | Pay transparency | ESG.
The first webinar in the series – "Wage gap and pay transparency: Must Have vs. Nice to Have" – will be held on December 12, 2024.
Details and registration can be found at: https://vonzanthierdachowski877.clickmeeting.com/luka-placowa-i-jawnosc-wynagrodzen-must-have-vs-nice-to-have/register.
