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Monday, August 31, 2026

EU Pay Transparency Transposition: Poland Rolls Out Local Recruitment Requirements as Broader Framework Emerges - The National Law Review

Takeaways

  • Poland has implemented portions of the EU Pay Transparency Directive, with recruitment-related requirements already in force since December 2025.
  • Pending broader Polish implementing legislation is expected to introduce additional requirements on employee information rights, pay structures, reporting and remediation.
  • Poland is particularly significant for multinational employers because its proposed broader framework includes stricter procedural requirements.
  • Employers should meet current recruitment obligations while preparing for the broader framework.

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Article

Implementation of the EU Pay Transparency Directive 2023/970 remains uneven across Europe. Although the June 7, 2026, transposition deadline has passed, several Member States have put individual requirements into force while broader implementing legislation is still being developed.

Poland is one of four Member States currently in this partial transposition category, along with Belgium, Czechia, and Estonia.

This article kicks off our series examining these four jurisdictions, focusing on important questions to employers:

  • What requirements are already in force?
  • What remains pending?
  • Where may national law go beyond the Directive?

Recruitment Requirements Already Apply

Poland was an early mover on recruitment transparency rules.

Recruitment-related amendments entered into force on Dec. 24, 2025, providing...



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