Pay transparency in Poland
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Pay information requests Partly in force
Own pay level and sex-disaggregated average pay levels for workers performing the same work or work of equal value (proposed under UC127).
Check the scope of what has commenced.
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Time to respond Without undue delay, at most 30 days for initial information and clarification (proposed)
Every request starts a clock. Answering one needs pay structures and equal-value groupings that already exist.
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Salary history questions are banned
Applicants learn the pay range before the interview, and employers may not ask what they earn today.
Poland has moved in two stages. Recruitment-stage pay transparency rules are already in force, effective from 24 December 2025, under the Act of 4 June 2025 amending the Labour Code. A wider equal-pay bill, known as UC127, would add reporting duties, an employee pay-information right and joint pay assessments, but it is still pending and not yet law.
The enacted piece covers what happens before someone signs an offer: pay ranges shared with candidates, a ban on asking about salary history, gender-neutral job titles and nondiscriminatory recruitment practices. It does not yet touch what happens after someone joins, such as ongoing reporting or comparator pay information for existing staff.
For now, it helps to think of Poland as two separate tracks: the recruitment rules that already apply to you, and the UC127 package that you should watch closely without treating it as binding.
The measure
- Law or measure
- Recruitment-transparency Act of 4 June 2025; equal-treatment Labour Code amendment of 19 June 2026; broader UC127 equal-pay bill pending
- Core obligations start
- 24 Dec 2025 (recruitment rules)
- Who is covered
- Adopted recruitment duties apply broadly; the remaining pay-structure, information and reporting duties are pending
What the law requires
- Pay range before the interview Source for: Pay range before the interview
- Salary history questions banned Source for: Salary history questions banned
- Pay information requests, Without undue delay, at most 30 days for initial information and clarification (proposed) to respond Source for: Pay information requests, Without undue delay, at most 30 days for initial information and clarification (proposed) to respond
- Gap reporting from 100 employees Source for: Gap reporting from 100 employees
- Joint pay assessment at a 5.0% gap Source for: Joint pay assessment at a 5.0% gap
How Poland differs from the Directive
Recruitment rules live since 24 December 2025. Separate enacted equal-treatment amendment Dz.U.2026/1046 starts 5 November 2026, with revised remedies, conditional proof and prevention; employers have six months to adapt internal rules. UC127 remains proposed: 30-day information replies; twelve paid months before request month; nominal contractual hours and specified benefit exclusions; below-50 progression criteria on request within 30 days. Ordinary reporting 31 March versus special first dates 7 June 2027 (150+) /2031 (100-149). JPA uses fixed September/October/November milestones.
What this means for employers
Because the recruitment rules are already in force, your hiring process needs attention now. That means job postings, interview practices and offer letters should reflect the new pay-range disclosure duty and the ban on asking about salary history. The rest of the picture, including reporting, employee pay information rights and joint pay assessments, is still shaped by a bill that has not passed, so none of it is mandatory yet.
- Update hiring materials: build pay-range disclosure and the salary-history ban into job postings, recruiter scripts and offer letters.
- Check job titles and criteria: make sure they are gender-neutral and based on objective factors, as the recruitment rules require.
- Watch UC127, don’t act on it yet: it would introduce a pay information right, reporting from 100 employees, and a 5% pay-gap trigger for a joint pay assessment, but none of this is enacted.
- Avoid premature builds: hold off finalizing reporting or joint pay assessment processes around numbers that could still change before UC127 passes.
- Know who enforces what: the Ministry of Family, Labour and Social Policy and the National Labour Inspectorate oversee these rules, with the Commissioner for Human Rights acting as equality body.
Enforcement and open questions
- Competent authority
- Ministry of Family, Labour and Social Policy; National Labour Inspectorate
- Equality body
- Current Commissioner for Human Rights remains separate; UC127 proposes a Commission for Counteracting Discrimination in Employment under Article 18(3) of the equal-treatment Act.
- Penalties
- UC127 Article 59 proposes PLN 2,000-60,000 fines for specified job-evaluation, criteria/information, reporting, JPA/remediation and privacy-process failures. Article 16 separately voids pay-secrecy restrictions; Article 59 does not expressly list Article 16 as its own offence.
- What could still change
- Official UC127 project summary remains a draft; planned Q4 2026 Cabinet consideration is not adoption. Full 29 April 2026 operative DOCX re-read from previously supplied official file; live RCL dossier/direct files return 503, so latest-version/stage not certified. Six-month commencement conflicts with fixed 7 June 2027 first deadline and commencement-year data period. Final indicator regulation/template/GUS operation and specific litigation-cost protection remain unverified. Dz.U.2026/1046 is enacted but starts 5 November, not yet live on this 4 November review; reconcile its overlapping remedies/proof with any final UC127.
Common questions
Is Poland's pay transparency law already in force?
Part of it is. The recruitment-stage rules from the Act of 4 June 2025 are in force as of 24 December 2025. The broader equal-pay bill, UC127, which would cover reporting and employee pay-information rights, is still pending and not yet law.
What do Poland's recruitment pay transparency rules actually require?
Employers must give candidates the initial pay amount or range based on objective, gender-neutral criteria, and cannot ask about pay in the applicant's current or previous job. Job titles and recruitment practices also need to be gender-neutral and nondiscriminatory. These duties are already in force.
Will Poland require gender pay gap reporting?
Not yet. The pending UC127 bill proposes mandatory reporting starting at 100 employees, with the employer preparing the report through an IT tool made available by a monitoring body with support from Statistics Poland. No first reporting dates have been set yet.
What pay information would employees get under Poland's proposed rules?
UC127 proposes a right for workers to see their own pay level and sex-disaggregated average pay for people doing the same work or work of equal value. This right is not yet in force, it exists only as a proposal.
What would trigger a joint pay assessment in Poland?
UC127 proposes a 5% pay gap at category level as the trigger, along with additional cumulative conditions. This is a proposed rule, not an obligation currently in force.
Who enforces pay transparency rules in Poland?
The Ministry of Family, Labour and Social Policy and the National Labour Inspectorate are the competent authorities. The Commissioner for Human Rights serves as the equality body.
- Pay information request right Art. 7(1)
- Partly in force
- Response deadline Art. 7(4)
- Without undue delay, at most 30 days for initial information and clarification (proposed)
- Salary range in recruitment Art. 5(1)
- Yes
- Salary history questions banned Art. 5(2)
- Yes
- Joint pay assessment trigger Art. 10(1)
- 5.0%
Own pay level and sex-disaggregated average pay levels for workers performing the same work or work of equal value (proposed under UC127).
4 Nov 2026 deep review. Proposed UC127 rules verified against complete previously supplied official 29 April 2026 DOCX (74 articles); live RCL returned503, latest-version status not certified. Recruitment law/current baseline kept separate. PL-DEEP-20261104070156
Read the sourceThe employer must answer in writing within this period.
4 Nov 2026 deep review. Proposed UC127 rules verified against complete previously supplied official 29 April 2026 DOCX (74 articles); live RCL returned503, latest-version status not certified. Recruitment law/current baseline kept separate. PL-DEEP-20261104070156
Read the sourceApplicants receive the pay or pay range before the interview, based on objective, gender-neutral criteria.
4 Nov 2026 deep review. Proposed UC127 rules verified against complete previously supplied official 29 April 2026 DOCX (74 articles); live RCL returned503, latest-version status not certified. Recruitment law/current baseline kept separate. PL-DEEP-20261104070156
Read the sourceWhether employers are prohibited from asking applicants about their current or previous pay.
4 Nov 2026 deep review. Proposed UC127 rules verified against complete previously supplied official 29 April 2026 DOCX (74 articles); live RCL returned503, latest-version status not certified. Recruitment law/current baseline kept separate. PL-DEEP-20261104070156
Read the sourceThe unjustified gap that obliges the employer and worker representatives to assess pay together.
4 Nov 2026 deep review. Proposed UC127 rules verified against complete previously supplied official 29 April 2026 DOCX (74 articles); live RCL returned503, latest-version status not certified. Recruitment law/current baseline kept separate. PL-DEEP-20261104070156
Read the source- Reporting threshold
- 100 employees
- Reporting model
- Proposed employer-calculated Operational data-production and filing model for pay-gap reporting: employer-calculated, authority-calculated, hybrid, proposed, pre-existing or absent.
- First report, 250 or more employees
- 7 Jun 2027 (proposed; commencement-dependent first period)
- First report, 100 to 149 employees
- 7 Jun 2031 (proposed)
- Metrics required
- EU seven only Art. 9(1): Seven metrics: mean gap; variable-component gap; median gap; median variable gap; variable-pay participation by sex; quartile distribution by sex; category-level gap split basic and variable.
- Pre-existing regime
- Current Labour Code: equal pay Article 183c, own-pay calculation-document access Article 85 §5, equal-treatment compensation Article 183d and anti-retaliation Article 183e. Recruitment rules live 24 December 2025. Separate enacted Dz.U.2026/1046 changes remedies, conditional proof and prevention from 5 November 2026; it does not enact UC127 reporting/information/JPA.
- Formal transposition stage
- Partly in force
- Scope
- Specific Directive provisions only
Next milestone
5 November 2026: separate Dz.U.2026/1046 equal-treatment amendment commences; Article 4 gives six months to adapt internal rules. For UC127, verify latest RCL text and actual Cabinet/Sejm/publication, reconcile first-report timing, and obtain final indicator regulation/template and GUS tooling.
Primary sources
- Recruitment-transparency Act of 4 June 2025; equal-treatment Labour Code amendment of 19 June 2026; broader UC127 equal-pay bill pending Primary source, checked 4 November 2026
- Formal transposition stage Partly in force · in force · High confidence
- Core employer obligations Partly operational · in force · High confidence
- Transposition scope Specific Directive provisions only · in force · High confidence
- Salary range in recruitment Yes · in force · High confidence
- Salary history questions banned Yes · in force · High confidence
- Pay information request right Yes · proposed · High confidence
- Response deadline Without undue delay, at most 30 days for initial information and clarification (proposed) · proposed · High confidence
- Reporting threshold 100 · proposed · High confidence
- First report, 250 or more employees 7 Jun 2027 (proposed; commencement-dependent first period) · proposed · High confidence
- First report, 100 to 149 employees 7 Jun 2031 (proposed) · proposed · High confidence
- Reporting model Proposed employer-calculated · proposed · High confidence
- Joint pay assessment trigger 5.0% · proposed · High confidence
- Info reference period Rolling period · proposed · High confidence
- Info pay basis Actual remuneration paid / earned · proposed · High confidence
- Info pay components scope Different / modified · proposed · High confidence
- Info request frequency At any time / no stated limit · proposed · High confidence
- Info employee reference period eligibility Article 14 uses the twelve months of paid remuneration preceding the request month; no minimum one-year service condition or request-frequency limit is stated. Article 2(3) counts actual pay for the period worked for that employer. · proposed · High confidence
- Info normalisation method Actual gross pay over the twelve months of paid remuneration preceding the request month, with hourly pay divided by nominal contractual working hours appropriate to the employment period; not an actual-hours-worked denominator (draft Articles 2 and 14). · proposed · High confidence
- Reporting reference period Previous calendar year · proposed · High confidence
- Reporting pay basis Actual remuneration paid / earned · proposed · High confidence
- Reporting pay components scope Different / modified · proposed · High confidence
- Reporting population basis Article 19 uses annual work units with FTE and partial-year fractions. User employers count temporary-agency workers; agencies exclude assigned workers from their own size calculation. Reporting ordinarily covers the preceding calendar year. · proposed · High confidence
- Reporting normalisation method Actual gross annual pay plus hourly levels using nominal contractual hours appropriate to employment duration. Employer-size annual work units prorate full months by months/12 and FTE, and partial months by days/year and FTE. Detailed report-indicator formulas are delegated to a future regulation (draft Articles 2, 19 and 21). · proposed · High confidence
- Employer required input data Actual payroll, sex, objective equal-value category, base and supplementary/variable pay, excluded uniform unconditional and termination benefits, nominal contractual hours, FTE and employment dates, temporary-worker assignments, REGON/NIP/PESEL employer identifiers and management confirmation. Maintain rolling request-month data separately from calendar-year reporting. · proposed · High confidence
- First data period needed Article 72: first 150+ report by 7 June 2027 covers the period from commencement to the end of that calendar year; first 100-149 report by 7 June 2031 covers the preceding calendar year. Article 74 proposes commencement six months after publication. The fixed 2027 deadline and commencement-dependent first period need reconciliation; do not assume a full 2026 first period. · proposed · High confidence
- Own pay information Yes · unclear · High confidence
- Comparator information Yes · proposed · High confidence
- Comparator information start Six months after final law publication (proposed; no enacted date) · proposed · High confidence
- Annual average information start Six months after final law publication (proposed; annual and hourly rolling-period outputs) · proposed · High confidence
Change history
Recent updates
Poland: equal-treatment changes start on 5 November; wider pay-transparency bill remains draft
An enacted Labour Code amendment changes equal-treatment remedies, proof and prevention from 5 November 2026. Poland’s broader UC127 information, reporting and joint-assessment duties remain proposed.
Polish draft clarifies 30-day pay-information replies and first-report rules
Poland’s UC127 draft specifies a 30-day information deadline, a rolling remuneration period and nominal-hour calculations.
This page is maintained by Evenpay from official primary sources and reviewed before publication. It is general information, not legal advice. Requirements vary by member state and change as national laws progress; figures described as proposed are subject to amendment.
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