Pay Transparency and the New Labour Code Regulations – See What’s Changing - JWW Accounting office Poland, Wroclaw, Warsaw

Pay Transparency and the New Labour Code Regulations – See What’s Changing

The new provisions of the Polish Labour Code, require employers to provide candidates with information about salary ranges and to share relevant parts of the remuneration regulations. Contrary to earlier expectations, however, the law does not introduce an obligation to include salary information directly in job advertisements. Below we present the key changes that will apply from 24 December 2025.

Salary Information — Mandatory, but Not Necessarily in the Job Posting

The newly added Article 183ca of the Labour Code requires employers to provide candidates with information on:

the amount of remuneration, its starting value, or the salary range determined on the basis of objective and gender-neutral criteria,
the provisions of the collective bargaining agreement or the remuneration regulations, if applicable.

The definition of remuneration is broad — it covers all components and benefits related to work, both monetary and non-monetary.

Employers must provide this information in paper or electronic form, sufficiently in advance to allow the candidate to engage in informed negotiations.

This obligation may be fulfilled at three stages:

in the job advertisement,
before the job interview, if no advertisement was published or it did not contain salary information,
before establishing the employment relationship, if the obligation has not been fulfilled earlier.

The intention of this solution is to ensure candidates have access to essential information before salary negotiations begin. However — contrary to the goals of the EU Directive — the Polish regulations do not require salary ranges to be made public in job postings, which limits the transparency of the recruitment process.

Neutrality and Non-Discrimination in Recruitment

Employers will be required to ensure that:

job advertisements and job titles are gender-neutral (e.g., “implementation specialist”),
the entire recruitment process is conducted in a non-discriminatory manner.

This aligns with the purpose of the Directive, which aims to eliminate bias and stereotypes already at the recruitment stage.

An End to Questions About Previous Earnings

The amendment introduces an explicit prohibition on employers requesting information about:

the salary earned with the current employer,
remuneration from previous employment relationships.

This is one of the most practical and necessary changes. Until now, questions regarding salary history could perpetuate pay inequalities — particularly for women, who statistically experience the gender pay gap more often.

What Does This Mean for Employers?

Although the new regulations do not fully implement the Directive’s vision, they still represent a significant shift in recruitment practices. Employers should:

adjust the content of job postings and recruitment processes,
develop internal guidelines for providing salary information,
verify the neutrality of language used in recruitment communication,
train recruiters on the prohibition of asking about salary history.

Failure to disclose salaries is punishable by fines ranging from PLN 1,000 to PLN 30,000.