By 7 June 2026 at the latest, all EU member states must fully implement into national law the provisions resulting from the Pay Transparency Directive. Meanwhile, the latest labour market survey conducted by SD Worx shows how prepared employers are in 2026 and how employees approach the upcoming changes.
In one month, on 7 June 2026, the deadline expires for the full transposition into national law of Directive (EU) 2023/970 of the European Parliament and of the Council on pay transparency, which entered into force on 6 June 2023. Poland has already implemented some of its provisions into the Polish legal system, including rules concerning the use of gender-neutral job titles in job advertisements and the indication of salary ranges.
By 7 June this year, the remaining EU guidelines should also be implemented locally, including provisions granting every employee the right to request from their employer information on the average pay levels of employees performing the same or comparable work in a given company, broken down by gender. In addition, larger employers, employing more than 100 people, are to be subject to an annual gender pay gap reporting obligation. It is already clear that this deadline will not be met in Poland.
This week, a new draft act implementing the directive in Poland was published. It shows that employers will be given six months to prepare for the new obligations, as a six-month vacatio legis has been introduced. Taking into account this vacatio legis and earlier announcements by the Ministry that the new regulations are to apply from the beginning of 2027, everything indicates that the act may be adopted before the summer holidays so that it can enter into force at the start of 2027.
The postponement of the directive’s implementation deadline will give companies more time to prepare. This additional time should be used to organise pay structures and design new processes. Preparing an organisation for the new obligations may prove quite time-consuming.
Employers must, among other things, verify whether job roles have been evaluated and, if so, whether mandatory criteria have been applied. In practice, most job evaluation processes do not take working conditions into account. Companies will also need to determine the criteria used when granting pay rises, verify where pay inequalities exist and assess whether there are objective reasons for these differences. And this is only the beginning.
“Employers will also need to organise the process for providing individual information on pay levels. This process should begin with an analysis of all components of remuneration and work-related benefits, as not all of them will need to be included for the purpose of providing information. The same applies to calculating the pay gap. It is already worth checking whether a pay gap exists in the organisation, and if so, at what level and whether there are objective reasons for differentiating employee pay,” says Katarzyna Wilczyk, Senior Lawyer at Raczkowski law firm.
Significant challenges also await companies operating within capital groups. The “single source” principle to be introduced by the Polish act may force such entities to change their decision-making processes in the area of remuneration. If one company in a group, including a foreign company, imposes rules on pay, bonuses or raises on other companies in Poland, then employees of the Polish company will be able to compare their pay with that of employees of the company that sets these rules.
These are key issues that will need to be resolved. Even assuming, in line with the new draft act, that the new obligations will start to apply at the beginning of 2027, there is not much time to prepare. Organisations have gained at least an additional six months, but the sooner companies begin analysing their pay structures and internal processes, the more efficiently and safely they will be able to adapt to the upcoming requirements.
One of the main goals of the directive is to eliminate pay differences between women and men. The EU legislator’s message is clear: employers must be transparent about pay and take action where unjustified gender pay differences exist. So far, only a few EU member states have transposed these provisions into national law.
Pro-employee law without strong social awareness
Although pay transparency has been present in public debate for several years, the latest labour market data are surprising when it comes to employees’ approach to this issue. The international “2026 HR & Payroll Pulse” survey conducted by SD Worx among 5,936 employers and 16,500 employees in 16 European countries shows that 58% of employees in Poland and as many as 66% in Europe are not aware of the Pay Transparency Directive and do not know what it means for their rights.
This shows that pay transparency may exist at a higher level in many organisations in terms of policy than in the everyday experience of employees.
Respondents were also asked how they perceive their pay. One in three Polish employees, or 32%, said that their salary is not fair compensation for the work they perform. Employees most often declaring that their pay is appropriate were those working in the United Kingdom, at 54%, Ireland, at 57%, and the Netherlands, at 58%. Less than half of Polish employees, 48%, said that their pay is fair compared with colleagues in similar positions within the company.
Employers versus the new law
The survey conducted by SD Worx, a leading European provider of HR solutions, shows not only that employers are not ready for the new regulations, but also that pay transparency is not their most important issue. Only 18% of Polish organisations list pay transparency among their top five pay-related priorities for 2026. Across Europe, the situation is similarly unfavourable, with only 19% of European companies identifying this area as a priority.
Moreover, only three in four Polish companies surveyed, or 74%, declare awareness of the EU Pay Transparency Directive. This result is nevertheless higher than the European average of 68%.
In addition, one in ten HR managers in Poland and Europe does not agree with the statement that their organisation is fully prepared to meet the directive’s requirements. However, most of them — 64% in Poland and 62% in Europe — declared that their company is fully prepared.
A clear disproportion is visible when company size is taken into account. Among companies employing more than 1,000 people, the share declaring full readiness is 68%, while among companies with fewer than 100 employees it is 52%.
At the same time, only one in five Polish and European organisations, 19%, offers employees specific tools aimed at making pay transparency visible, such as salary ranges or pay levels for specific roles.
Fair pay is also not the domain of all employers. Only 63% believe they pay their employees fairly. On average, 18% of Polish companies admit that they do not pay their employees fairly. Although 59% of organisations regularly analyse internal data to identify and eliminate pay differences, only 39% of employees believe that their organisation is genuinely committed to solving this problem.
Polish men show slightly more trust in this area, at 41%, than Polish women, at 37%. However, half of both men, 51%, and women, 50%, expect transparency to increase in the coming years.
Work in progress
Although legislative work on the full implementation of the EU directive is still ongoing, organisations should already be taking steps to ensure a smooth transition into the new legal reality. Systematic collection, analysis and comparison of pay data allows companies to identify potential pay inequalities more quickly and take targeted corrective action.
As a result, companies not only prepare better for upcoming regulations but also strengthen their attractiveness on the labour market. Pay transparency is playing an increasingly important role in attracting and retaining talent, as 74% of Polish employees consider it a very important or important factor when choosing an employer.
Transparency is an upcoming obligation, but also added value for companies. As the latest SD Worx survey shows, there are many areas in which both employers and employees need to catch up. At the same time, this is an element that will strengthen employers’ competitiveness, because already today three in four Polish women and men point to pay transparency as a factor influencing their choice of workplace.
To remain competitive on the market, organisations should already be taking action that brings them closer to transparency, including job evaluation and preparation of basic salary tables, even before the provisions of the EU directive are fully implemented into national law.
“It is worth using the potential and possibilities offered by modern technologies and artificial intelligence. Moving data from paper or Excel spreadsheets to professional HR systems can measurably improve the preparation of HR and payroll departments for new obligations, such as reporting related to the Pay Transparency Directive,” says Paulina Zasempa, People Country Lead at SD Worx Poland.
