Poland pay transparency status
Last reviewed 2026-10-16
Partly transposed — do not treat the rest as in force
Poland has transposed only part of the Directive. The rest is not in force.
Poland (Polska, PL), capital Warsaw, EU member since 2004. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. Pre-employment Labor Code amendments took effect on 24 December 2025. The rest remains a draft published on 4 May 2026.
What applies by employer size
Only part of the Directive is in force in Poland. The bands below are the Directive floor, not a list of duties already binding. Reporting and any measure the status note still calls a draft are not in force.
Fewer than 100 workers
Article 9 gender pay-gap reporting does not start below 100 workers. Article 5 (pay range or starting pay for applicants, and no pay-history questions) and Article 7 (worker right to pay-level information) are not limited to employers of 100 or more. That is the Directive floor, not a statement that the Member State already imposes it.
100 to 149 workers
Article 9 requires the employer to report the gender pay gap every three years. The Directive sets the first report for 7 June 2031. Joint pay assessment under Article 10 can follow an unjustified gap of at least 5 percent. National law must transpose the duty before it binds a private employer.
150 to 249 workers
Article 9 requires the employer to report the gender pay gap every three years. The Directive sets the first report for 7 June 2027. The same Article 10 joint-assessment rule can apply. National law must transpose the duty before it binds a private employer.
250 or more workers
Article 9 requires the employer to report the gender pay gap every year. The Directive sets the first report for 7 June 2027. The same Article 10 joint-assessment rule can apply. National law must transpose the duty before it binds a private employer.
Deadlines
Transposition deadline for Member States
7 June 2026
Directive (EU) 2023/970. A missed deadline does not by itself create private-employer duties. Source
First Article 9 report, 250 or more workers
7 June 2027, then yearly
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
First Article 9 report, 150 to 249 workers
7 June 2027, then every three years
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
First Article 9 report, 100 to 149 workers
7 June 2031, then every three years
Article 9 of Directive (EU) 2023/970. Applies as a national duty only once transposed. Source
Poland timing from the status snapshot
Pre-employment Labor Code amendments took effect on 24 December 2025. The rest remains a draft published on 4 May 2026.
Lockton table as of 23 September 2026. Not an official gazette. Source
Rules on 2026-10-16
Resolved from rule pack version 2026-09-23. Status is enacted, partial, draft, or none. A future effective date is not in force yet.
Pay range for applicants (Article 5)
Status: enacted. Effective 2025-12-24. Last reviewed 2026-10-16. In force on the review date.
Poland: Article 5 requires applicants to receive the initial pay or its range. The Directive does not limit this to employers of 100 or more. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
No pay-history questions (Article 5)
Status: enacted. Effective 2025-12-24. Last reviewed 2026-10-16. In force on the review date.
Poland: Article 5 prohibits asking applicants about their pay history. The Directive does not limit this to employers of 100 or more. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Worker right to pay-level information (Article 7)
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 7 gives workers a right to information on their pay level and average pay levels by sex for the same work. The Directive does not limit this to employers of 100 or more. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — fewer than 100 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 9 does not require gender pay-gap reporting below 100 workers. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 100 to 149 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 100 to 149 workers the Directive sets the first report at 2031-06-07. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 150 to 249 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 150 to 249 workers the Directive sets the first report at 2027-06-07. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Gender pay-gap reporting (Article 9) — 250 or more workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 9 requires gender pay-gap reporting on the Directive timetable once national law transposes it. For 250 or more workers the Directive sets the first report at 2027-06-07. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — fewer than 100 workers
Status: none. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 9 does not require a joint pay assessment below 100 workers. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 100 to 149 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 100 to 149 workers the Directive sets the first report at 2031-06-07. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 150 to 249 workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 150 to 249 workers the Directive sets the first report at 2027-06-07. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Joint pay assessment (Article 10) — 250 or more workers
Status: draft. Effective 2026-09-23. Last reviewed 2026-10-16. Not in force on the review date.
Poland: Article 10 can require a joint pay assessment after an unjustified gap of at least 5 percent, once reporting is a national duty. For 250 or more workers the Directive sets the first report at 2027-06-07. Snapshot: Amendments to the Labor Code to transpose pre-employment provisions under the Directive took effect from 24 December 2025. A revised draft law to transpose the remaining provisions was published on 4 May 2026. A draft or a missing statute is not an employer duty.
Sources
- Directive (EU) 2023/970 on pay transparency (as of 2023-06-06)
- Lockton, EU Pay Transparency Directive — implementation status (table as of 23 September 2026) (as of 2026-09-23)
Directive guides · Gender pay gap calculator
Informational only. This is not legal advice, not a legal opinion, and not a substitute for reading the national statute or instructing counsel. Statutory claims on this page cite Directive (EU) 2023/970 or the Lockton status snapshot and carry a last-reviewed date.