On 25 November 2025, the Polish government published the principal assumptions intended to underpin forthcoming legislation implementing the outstanding provisions of the EU Pay Transparency Directive 2023/970. The government has commenced the process of transposing the directive into national law. The first measures will be introduced by way of amendments to the existing Labour Code, and will come into effect 24 December 2025.

Quick Hits

• Rather than simply amending the Labour Code, the Polish government plans to implement EU Pay Transparency Directive 2023/970 in a standalone piece of legislation.
• Employers will be obliged to go through a process of job evaluation, consisting of four core basic criteria. The plan will also see the introduction of a “Job Evaluation Tool.”
• A failure to comply with the changes may result in a fine of up to PLN 60,000.
• Generally, the draft law is likely to align with the provisions set out in the EU Pay Transparency Directive.

The Polish government has strongly affirmed that employers will be required to undertake job evaluations for the purpose of determining whether employees perform work of equal or comparable value. In this regard, the proposal introduces a new analytical tool for job evaluations, intended to support employers in meeting this obligation. However, employers retain the discretion to adopt an alternative methodology, provided that such methodology is analytical, gender-neutral, and objectively justified.

Importantly, any...

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