JP Weber

New employer obligations: pay transparency and neutrality in job advertisements.

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New employer obligations: pay transparency and neutrality in job advertisements.

On May 9, 2025, the Polish Sejm adopted an amendment to the Labour Code, representing a partial implementation of the EU directive on pay transparency and equality.

The aim of the following regulations is to increase transparency in the recruitment process by imposing an obligation on employers to inform candidates about the amount of remuneration (or its range) and the terms of remuneration before employment, as well as to ensure gender neutrality in job advertisements and eliminate discrimination in the recruitment process. These changes are also intended to strengthen pay equity and support informed negotiations between the employer and the candidate. The bill is currently in the Senate, where further work is being carried out; nevertheless, it is worth starting preparations for possible changes now, in order to be able to adapt to the new regulations in a timely manner.

The employer will be required to clearly inform the job applicant:

  • about the amount of remuneration or its range (provided on the basis of objective and neutral criteria, e.g. regardless of gender),

  • about the provisions of the collective labor agreement or remuneration regulations – if applicable in the given company.

When must this information be provided?

Depending on the situation, the employer must do so in the advertisement or before the interview, if there was no advertisement, or before employment, if there was neither an advertisement nor an interview, or if information about the remuneration was not provided earlier.

Neutrality of job advertisements and recruitment

  • Job advertisements and job titles must be gender-neutral, e.g. “hiring waiter/waitress.”

  • The entire recruitment process must be free from discrimination, e.g. without indicating in the job advertisement that “we are looking for an employee up to 40 years old.”

Sanctions

The original version of the bill provides for a fine ranging from PLN 1,000 to PLN 30,000 for failing to include salary information in the advertisement or for concluding a contract with a salary lower than declared.

The employer may request information about previous employment but may not ask about the salary in the current or previous jobs. The changes will come into force 6 months after the law is published.

How we can help:

  • Reviewing and updating remuneration policies and collective labor agreements, in line with the new information disclosure obligations

  • Supporting audits and documentation of pay decisions, ensuring solid justification in the event of inspections or disputes

  • Adapting internal recruitment procedures to comply with upcoming requirements

  • Reviewing current job postings and HR materials

  • Preparing salary information for candidates

  • Delivering training for HR teams and hiring managers, with a focus on the practical aspects of applying the new rules

  • Monitoring the legislative process and providing regular updates on its progress and final outcome

JP Weber

Rafał Gołąb, Phd.

Rafał Gołąb, Phd.

Partner,
Attorney at Law

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