The draft legislation implementing the Pay Transparency Directive in Poland provides that all employers employing more than 100 full-time equivalent employees will be required to calculate gender pay gaps annually, both adjusted and unadjusted, in relation to adopted employee categories. Temporary workers must also be included in the headcount.

Information on pay gaps will be included in an annual report, though the frequency of submitting the report to the monitoring authority depends on the employer’s workforce size.

By 31 March of each year, employers will be required to provide information on adjusted pay gaps to employees and trade unions. Employers will also be obliged to present the methodology used to calculate the pay gaps.

If the adjusted pay gap in a given category is 5% or more and is not justified by objective, gender-neutral criteria, the employer will be required to take effective remedial measures within a specified timeframe, and may even be required to jointly assess remuneration with employee representatives in order to eliminate the gap.

Calculating pay gaps requires a number of decisions, including defining what constitutes remuneration and selecting the appropriate calculation methodology.

Contact us for assistance with preparing your organisation for these processes.

Find more articles in PRO HR January 2026.