Poland Salary Transparency Law 2025: New Recruitment Rules December 24

From December 24, 2025, revolutionary changes in labor law will come into force in Poland, fundamentally transforming the recruitment process. The amendment to the Labor Code, which partially implements EU Directive 2023/970 on pay transparency, introduces an obligation for pay transparency at the employee search stage.

These changes aim to eliminate pay discrimination, increase labor market transparency, and equalize opportunities for all candidates. For employers, this means the necessity of a thorough review of compensation policies and adjustment of recruitment procedures to new legal requirements.

Important: The amendment comes into force on December 24, 2025. Full implementation of the EU directive must occur by June 7, 2026, which means further changes next year.

Key Changes in the Recruitment Process

Obligation to Inform About Compensation

The most important change concerns the obligation to inform candidates about anticipated compensation. The employer will be required to provide candidates with information about:

• Anticipated compensation – initial amount or range (so-called salary brackets)
• All compensation components – not just the base, but also bonuses, allowances, benefits
• Work-related benefits – both monetary and non-monetary (e.g., private medical care, sports passes, insurance)
• Provisions of collective agreements – if the employer is covered by a collective labor agreement or remuneration regulations

When Should Information Be Provided?

Information about compensation should be provided to candidates:

• Preferably in the job posting – although not absolutely required, it significantly facilitates the recruitment process
• No later than before the recruitment interview begins – in paper or electronic form
• With appropriate advance notice – so the candidate can review the information and prepare for negotiations

Prohibition on Asking About Salary History

The new regulations introduce a categorical prohibition on asking candidates about their salary in current or previous workplaces. This obligation stems from the amendment to Article 22¹ of the Labor Code.

The purpose of this regulation is to prevent perpetuation of unfair salary rates and increase equal opportunities in access to employment. Candidates who were previously undervalued in terms of pay will no longer be automatically discriminated against in new workplaces.

Gender Neutrality in Job Postings

Job postings must be formulated in a gender-neutral manner. Employers are required to:

• Use neutral job titles (e.g., “specialist” or impersonal form)
• Avoid wording suggesting a preferred candidate gender
• Base compensation criteria on objective, neutral factors

Employees’ Right to Information

The new regulations also give current employees the right to obtain information about:

• Compensation criteria applied in the company
• Average salaries for similar positions
• Salary levels broken down by gender (in larger companies)

Penalties for Violating Regulations

Failure to comply with new obligations may result in fines imposed by the National Labor Inspectorate. According to the Labor Code, financial penalties currently amount to:

The fine amount will depend on the nature and scale of the violation. Particularly severely punished will be:

• Lack of salary information in postings or at the recruitment stage
• Asking candidates about salary history
• Offering compensation lower than declared brackets
• Using salary confidentiality clauses in contracts

Consequences for Employers

The new regulations pose a number of challenges for employers:

• Need to revise pay policy – many companies will have to organize their compensation structure and eliminate unjustified differences
• Risk of team conflict – disclosure of brackets may cause dissatisfaction among employees earning below market rates
• Employee attrition – people who discover they are underpaid may seek better offers
• Need to train HR staff – recruiters and managers must be prepared for compensation discussions
• Documentation updates – work regulations, job posting templates, and recruitment procedures require adjustment

Despite the challenges, salary transparency also brings tangible benefits:

• More efficient recruitment – salary brackets eliminate candidates with excessively high expectations, speeding up the process
• Strengthened employer branding – transparency builds trust and the image of a fair employer
• Competitive advantage – companies with clear pay policies attract better candidates
• Greater team motivation – employees who understand compensation principles feel more valued
• Reduced risk of disputes – clear compensation criteria minimize conflicts and claims

Market Data

Market research clearly shows that salary transparency is expected by candidates:

In Poland, the pay gap between women and men is currently about 4.5-8.5% (depending on methodology), while the EU average is 13%. The new regulations aim to further reduce these differences.

How to Prepare for Changes?

Step 1: Compensation Policy Audit

Conduct a comprehensive analysis of the current salary structure in your organization:

• Inventory all positions and compensation levels
• Identify unjustified differences in pay for similar positions
• Check if there is a gender pay gap
• Analyze all compensation components and benefits

Step 2: Job Evaluation

Job evaluation is the foundation of fair pay policy. This process involves:

• Evaluating each position according to objective criteria (competencies, responsibility, working conditions)
• Creating a coherent job hierarchy
• Determining salary ranges for each level
• Establishing clear rules for promotions and raises

Step 3: Documentation Updates

Adjust internal documents to new requirements:

• Modify job posting templates – add section with salary brackets
• Update recruitment procedures – remove questions about salary history
• Develop or amend compensation regulations
• Prepare templates for candidate information about compensation components
• Remove salary confidentiality clauses from employment contracts

Step 4: Team Training

Prepare HR department employees and managers for new obligations:

• Conduct training on new regulations
• Practice recruitment interviews taking salary transparency into account
• Prepare answers to typical candidate questions about compensation
• Develop internal communication strategy for current employees

Step 5: Communication with Employees

Transparent implementation of changes requires appropriate communication:

• Inform the team about upcoming changes and their justification
• Explain compensation criteria used in the company
• Ensure opportunity to ask questions and express concerns
• Be prepared for conversations about salary equalization

Further Changes in 2026

The regulations in force from December 24, 2025, are only the first stage of implementing the EU directive. By June 7, 2026, Poland must implement further requirements, including:

Pay Gap Reporting Obligation

• Companies employing 250+ employees – will report pay gap annually
• Companies employing 100-249 employees – will report pay gap every 3 years

Joint Pay Assessment

If the pay gap exceeds 5% and cannot be justified by objective criteria, the employer will have to – in cooperation with employee representatives – conduct a joint pay assessment within 6 months.

Strengthened Employee Protection

• Burden of proof shift – in pay discrimination cases, the employer will have to prove lack of discrimination
• Right to compensation – employees will be able to claim back pay and damages
• Report availability – pay gap reports will be available to employees and supervisory bodies

What Will Be Best Practices?

Formulating Salary Brackets

When determining salary ranges, it’s worth:

• Avoiding too wide brackets (difference should not exceed 30-40%)
• Clearly defining factors affecting position within the range (experience, competencies)
• Including all compensation components (base + variable + benefits)
• Regularly updating brackets based on market data

Communication with Candidates

During recruitment interviews:

• Prepare detailed information about the compensation package
• Explain how the candidate can reach the upper bracket limit
• Be prepared for questions about the bonus system and benefits
• Document provided information

Managing Team Expectations

To minimize the risk of internal conflicts:

• Prepare a plan to equalize salaries for underpaid employees
• Create a clear development and promotion path
• Regularly communicate compensation principles
• Conduct systematic salary reviews

Implementation Checklist

Use the checklist below to ensure your organization is ready for changes:

• ☐ Conducting compensation policy audit
• ☐ Job evaluation
• ☐ Establishing salary ranges for all positions
• ☐ Updating job posting templates
• ☐ Modifying recruitment procedures
• ☐ Developing/updating compensation regulations
• ☐ Removing salary confidentiality clauses from contracts
• ☐ Training HR department and managers
• ☐ Preparing internal communication strategy
• ☐ Informing team about changes
• ☐ Preparing information templates for candidates
• ☐ Verifying gender neutrality of job titles
• ☐ Preparing for pay gap reporting (2026)
• ☐ Consulting with lawyer/legal advisor

Support in Implementing Changes

As a law firm specializing in HR matters, we offer comprehensive support in adapting your company to new pay transparency regulations.

Our Competencies

Labor and HR Law:

• Compensation policy audit and adaptation to new requirements
• Preparation of compensation regulations and recruitment procedures
• Job evaluation and creation of pay structures
• Representation before the National Labor Inspectorate

Tax Law:

• Tax optimization of compensation and benefits systems
• Advisory on personal income tax (PIT)
• Structuring motivational packages and bonus programs
• Consultations on social security (ZUS) and insurance contributions

Comprehensive Approach:

• Training for HR departments and management staff
• Internal communication strategies about pay changes
• Preparation for pay gap reporting (2026)
• Ongoing legal and tax advisory on employment matters

We combine legal knowledge with tax and HR expertise – we comprehensively support your company

Summary

Changes in recruitment regulations introduced from December 24, 2025, represent a fundamental transformation of the Polish labor market. The obligation of salary transparency, prohibition on asking about salary history, and requirement for gender neutrality are not only new legal obligations but above all an opportunity to build a more fair and transparent work environment.

For employers, it is crucial to use the time until December 2025 for comprehensive preparation of the organization for changes. This requires not only adjustment of formal documentation but above all conducting a pay policy audit, job evaluation, and training teams responsible for recruitment.

It’s worth remembering that this is only the first stage of implementing the EU directive – in 2026 we can expect further changes, including the obligation to report pay gaps. Companies that invest now in building a transparent and fair compensation system will be better prepared for future requirements and gain a competitive advantage in attracting the best talent.

Salary transparency is not only a legal obligation – it’s an investment in organizational culture, employer branding, and the company’s long-term success in the labor market.

Legal Basis

• Act of June 4, 2025, amending the Act – Labor Code (Journal of Laws 2025, item 807)
• Directive (EU) 2023/970 of the European Parliament and of the Council of May 10, 2023, on strengthening the application of the principle of equal pay
• Labor Code (Articles 18³ᶜ, 22¹, 94³ᵃ)