EU Pay Transparency Transposition: Poland Rolls Out Local Recruitment Requirements as Broader Framework Emerges

Takeaways

• Poland has implemented portions of the EU Pay Transparency Directive, with recruitment-related requirements already in force since December 2025. 
• Pending broader Polish implementing legislation is expected to introduce additional requirements on employee information rights, pay structures, reporting and remediation. 
• Poland is particularly significant for multinational employers because its proposed broader framework includes stricter procedural requirements. 
• Employers should meet current recruitment obligations while preparing for the broader framework.

Related links

• EU Pay Transparency: Member States Near Transposition Finish Line 
• EU Pay Transparency + Uneven Member State Adoption: Four Points for Multinational Employers

Article

Implementation of the EU Pay Transparency Directive 2023/970 remains uneven across Europe. Although the June 7, 2026, transposition deadline has passed, several Member States have put individual requirements into force while broader implementing legislation is still being developed.

Poland is one of four Member States currently in this partial transposition category, along with Belgium, Czechia, and Estonia.

This article kicks off our series examining these four jurisdictions, focusing on important questions to employers:

• What requirements are already in force? 
• What remains pending? 
• Where may national law go beyond the Directive?

Recruitment Requirements Already Apply

Poland was an early mover on recruitment transparency rules.

Recruitment-related amendments entered into force on Dec. 24, 2025, providing applicants with greater access to compensation information during the hiring process. The reforms require employers to provide applicants with information concerning the initial salary or salary range applicable to the position. The information must be provided sufficiently early in the recruitment process to support transparent pay negotiations.

The rules also address the recruitment process more generally, including imposing restrictions on seeking information concerning candidates’ previous compensation.

For multinational employers, these requirements should already be reflected in recruitment practices in Poland, rather than deferred pending comprehensive transposition.

Broader Transposition Remains Pending

These requirements are only part of Poland’s implementation of the Directive. The broader Polish proposal is expected to address employee rights to compensation information, objective and gender-neutral pay structures, gender pay gap reporting, and procedures for addressing unexplained pay disparities.

Those future requirements will make pay transparency relevant well beyond the recruiting process.

Poland’s Potential Gold-Plating

Poland is of particularly interest because its broader proposal contains several potentially significant procedural departures from the Directive, including:

• A proposed 30-day deadline for responding to employee pay-information requests; 
• A fixed March 31 annual notice date; and 
• Tighter deadlines for responding to requests for explanations from trade unions or equality bodies.

These provisions illustrate how “gold-plating” does not necessarily mean dramatically expanding the Directive substantive scope. More prescriptive procedural requirements can create meaningful operational challenges for multinational employers. For example, a company relying on a common European employee-information process may need to implement a shorter response timeline in Poland.

Importantly, these broader requirements remain under consideration and should not be regarded as final law.

What Employers Should Be Doing

Employers in Poland should comply with the requirements already in force while preparing for the broader legislation to come.

Organizations should:

• Review recruiting templates and practices; 
• Establish clear processes for communicating salary information to candidates; and 
• Ensure recruiters do not request prohibited salary-history information.

At the same time, employers should begin reviewing job architecture, compensation criteria, employee information procedures, and pay data to ensure that the organization is prepared to comply with broader requirements once they are enacted.

Employer Takeaway

Poland demonstrates why employers should not approach EU pay transparency implementation as a one-time compliance exercise tied to a single “effective date.” Some obligations are already in force, while others remain under development and could impose additional procedural requirements beyond those set out in the Directive.

Watch for the next installment in our series on Czechia, where a different portion of the transparency framework (protection for employees discussing their own pay) is already in force.

Please contact a Jackson Lewis attorney with any questions.