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Implementation of the Equal Pay Directive

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Implementation of the Equal Pay Directive

By 7 June 2026, Poland should implement the EU Pay Transparency Directive into its national legal system, which aims to ensure transparency of the pay system and equal pay for women and men. 

Under the directive, employees will, among other things, have the right to request information on their individual pay levels and the average pay levels for their occupational groups, broken down by gender.

This information should include employees performing the same work or work of equal value. Employees will have the right to obtain this information in writing, ensuring transparency and enabling monitoring of compliance with the principle of equal pay.

The employer, on the other hand, will be responsible for reporting in particular. The employer should prepare a report containing, among other things, the size of the gender pay gap, the size of the gender pay gap in the form of supplementary or variable components, the size of the gender pay gap in the form of supplementary or variable components.

Employers employing a specified number of employees in the following ranges:

  • ≥ 250 - for the first time by 7 June 2027 and then every year
  • 250 < > 150 - for the first time by 7 June 2027, and then every 3 years
  • 149 < > 100 - for the first time by 7 June 2031
  • < 100 - can meet reporting obligations voluntarily, although national law may require employers with fewer than 100 employees to provide information on remuneration. There is no information yet on how this issue will be resolved in the Polish legal system.

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JP Weber

Rafał Gołąb, Phd.

Rafał Gołąb, Phd.

Partner,
Attorney at Law

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