Will the obligation to report wages become as much of a challenge for companies as the Polish Order? In 2026, companies with more than 150 employees will have to tally wage data to prepare an annual report on the gender wage gap. Companies with more than 250 employees will have to submit such reports every year from 2027, and those with over 150 employees every three years. This means that the necessary data must be collected from January 2026. However, employers must first ensure that they can properly sort wage data. Hence for HR departments a new task of strategic importance for the company emerges.
Commentary: Marcin Mika, Director Growth & Client Success at ADP Poland
The wage gap issue and the related reporting has already been discussed with clients multiple times. Companies are gradually familiarizing themselves with the directive’s provisions and its emerging interpretations. The next step will be applying theory into practice- creating a plan on what and how to count in order to report. I assume that after the annual year-end processes- e.g., issuing PIT, we will observe a much more concrete interest in this issue.
Companies can start reviewing the structure of positions and their corresponding wages. It will clearly show the starting situation- how accurate the range of duties assigned to a given position and wage equality are in our company. For many companies, this will be the biggest challenge and will take the most time. However, it will also allow for an action plan to be started. The situation may be more difficult in smaller or family-owned companies, as multinational corporations have been introducing similar mechanisms for some time. I will not be surprised if the first visible consequence of wage transparency will be a change in position structures in many companies.
For example, “customer service representative” or “call center worker” is a very broad term that, within the same organization, can include both a person who does not need to have high qualifications and performs simple tasks, as well as someone carrying out tasks of high complexity. How to compare them, how to justify the wage gap between these people? It may turn out that new positions need to be introduced, existing ones broken down into separate categories, and new names that better reflect the tasks assigned to them, need to be introduced. This will mean that comparing employee wages will reach a completely new level. A new profession may even emerge, either temporarily or permanently, someone like an auditor of the company’s position structure who will manage these issues.
Starting such an audit early also has a financial aspect. If our structure is unclear and the associated wage disparity is large and unjustified, we will need to secure an adequate budget to fix the pay situation and avoid the consequences specified in the directive.
Of course, questions are already arising from clients, whether a provider of HR and payroll services will provide appropriate technological solutions that will facilitate reporting. The introduction of appropriate solutions at the level of HR and payroll software that will facilitate the counting of necessary data and generation of reports is obvious. But it must be emphasized that we do not yet have national regulations for the implementation of the directive, or even a project showing the direction we will go. Without this, it is difficult to plan changes and carry out programming work, as national regulations may define a specific required reporting method.
Source: https://ceo.com.pl/dyrektywa-o-jawnosci-wynagrodzen-puka-do-drzwi-firm-dzialy-kadr-i-plac-juz-maja-co-robic-49970
