A Company Car for Private Use Also Constitutes Remuneration

Autor

Łukasz Kuczkowski

Contact us

On 24 December, provisions enter into force requiring employers to inform job candidates of the remuneration they may receive in the position being recruited for.

For the purposes of these provisions, the concept of remuneration is very broad – consistent with the definition used for equal treatment, which moves somewhat away from the strict equivalence of work and payment. It includes not only basic salary but also all other components of remuneration, regardless of their name or nature, as well as other work-related benefits granted to employees in cash or in non-cash form.

Consequently, to correctly implement the new provisions, employers must first establish what constitutes remuneration. This will include not only the typical components, such as bonuses, rewards and allowances (seniority, shift, functional), as well as other supplements – particularly those exceeding statutory levels – and lump-sum payments for overtime or night work, but also medical care (beyond occupational health), life insurance, multisport cards (if financed from the employer’s own funds, not from the Social Benefits Fund), and a company car, or even a company phone with the right to use it for private purposes. On the other hand, purely social benefits (e.g. fruit Thursdays), benefits from the Social Benefits Fund, PPK or PPE schemes, and benefits related to working time (e.g. additional leave or remote work) are not included.

For employers with extensive benefits structures, determining this may be challenging.

Importantly, this classification will also matter when applying further provisions implemented under the Pay Transparency Directive in Poland. It is therefore advisable to carry out such an assessment now, in order to ensure transparency and consistency in the organisation’s approach.

Find more articles in PRO HR November 2025.