/>iAn act partially implementing the Pay Transparency Directive has been published and will enter into force in Poland on 24 December this year.
The act focuses on the pay transparency aspects of the Directive. Implementation details for aspects of the Directive relating to job evaluation and reporting are still awaited, with the government indicating that it intends to present a more comprehensive bill following the conclusion of the work by its working group by the end of 2025.
In the meantime, here is what we know so far about how Poland will implement transparency in relation to salaries and recruitment information and what this means for employers and recruiters.
Key Provisions in the New Legislation:
| Job Advertisements |
Both job titles and job advertisements must be gender-neutral. Recruitment processes must be conducted in a non-discriminatory manner. |
| Information To Be Shared With Candidates Prior to Employment |
Candidates Must Be Provided With Information in Writing Concerning: 2. Relevant provisions of the remuneration regulations or a collective bargaining agreement, i.e. those indicating the rules for remuneration applicable to the candidate. Timing and Formalities: This information must be provided to the candidate in a written or electronic form. The electronic form does not require a qualified electronic signature; other electronic forms of delivery, such as email or scan, are also acceptable. |
| Ban on Questions About Salary History | The employer may not ask the candidate for information about their remuneration at their current or previous employers. |
Steps That Employers Can Take Now To Prepare for Compliance With the New Transparency Legislation:
- Review advertisements and job titles used in the company and ensure that these are gender-neutral.
- Prepare a standard template for use in hiring processes which lists out all elements of remuneration and work-related benefits. The template should also contain an extract from the applicable regulations or collective bargaining agreement which sets out the rules for remuneration in the company.
- Train Talent Acquisition teams and managers with involvement in recruitment on the new requirements. Ensure any questions about current or previous pay are taken out of the standard interview process and ensure relevant personnel are aware that such questions will become unlawful under the new rules.
- Monitor further legislative work on the implementation of the Pay Transparency Directive in Poland, as additional obligations for employers may be introduced including gender pay gap reporting.
