At a Glance

• Poland is the first major economy in Europe to transpose portions of the EU Pay Transparency Directive into national law.
• Article 5 of the Directive addresses an employer’s pay transparency obligations for job applicants.
• Poland has largely adopted Article 5’s language and obligations with a few specific changes.

Just in time for the holiday rush, Poland is the first major economy in the region to carry out any portion of the European Directive (EU) 2023/970 on pay transparency (hereafter referred to as the “PTD”). Poland’s partial implementation of the PTD (officially titled Ustawa z dnia 4 czerwca 2025 r. o zmianie ustawy - Kodeks pracy, hereafter referred to as the “Act”) takes effect on December 24 and is focused solely on ensuring that Article 5 of the PTD is integrated into Polish national law. This article will unwrap the new obligations so there are no surprises for Polish employers.

What is Article 5 of the PTD?

Article 5 of the PTD specifically addresses the obligations of employers towards job applicants. Unlike other aspects of the PTD, Article 5 does not have a threshold limitation; it applies to all employers, regardless of employee headcount.

Pursuant to Article 5:

• Job applicants have a new right to receive information about (i) the job’s “initial pay or its range”—information that must be based on objective, gender-neutral criteria, and (ii) relevant provisions of the collective agreement (if applicable);
• Employers must provide the...

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