[Poland] Sejm for pay transparency at recruitment stage. How will the new regulations affect employers’ obligations?

On 9 May 2025, Sejm passed a significant amendment to the Labour Code. It introduces significant changes to recruitment processes and pay transparency. How will the new regulations affect the current obligations of employers? How to prepare for the changes?

The Act of May 9 amending the Labour Code has been submitted to Senate, and its entry into force may significantly affect the transparency of salaries at the recruitment stage. For employers, this means a new obligation to inform candidates about the salary offered for a given position. It will be necessary to provide the starting pay or its range, taking into account objective and non-discriminatory criteria, especially in terms of gender.

The obligation to disclose salaries at recruitment stage – what does it involve?

One of the key changes from the point of view of entrepreneurs is the introduction of the obligation to inform candidates about the proposed remuneration already at the recruitment stage. In accordance with the new art. 18 ^3ca Labour Code, employers will be required to provide:

• starting salary or salary range. This information must be based on objective and neutral criteria, with particular regard to gender equality;
• relevant provisions of the collective labour agreement or remuneration regulations if such apply in a given company.

Information about remuneration, including all salary components (monetary and non-monetary) and other work-related benefits, will have to be provided to the candidate in time in paper or electronic form:

1. in the job advertisement;
2. before the interview, if the job advertisement was not published or did not contain information about remuneration;
3. before entering into an employment relationship, if the information has not been provided earlier.

Gender neutrality of job advertisements and job titles

Another new requirement is to ensure that job advertisements and job titles are gender neutral. In practice, this may mean the need to use:

• dual forms (masculine and feminine), or
• descriptive job titles.

In addition, the new regulations will impose on employers the obligation to conduct the recruitment process in a non-discriminatory manner.

Prohibition on asking about candidates’ previous salary

The amendment is also to change the wording of Article 22(1) paragraph 1 point 6 of the Labour Code. This provision refers to personal data that a future employer may request from a job candidate.

After the change, employers will not be able to ask about the amount of remuneration in the current or previous places of work, i.e. information about remuneration in the current and previous places of work will be excluded from the course of previous employment.

Pay transparency and internal regulations – prepare your company for changes

In view of the upcoming legislative changes regarding pay transparency, employers should pay special attention to their internal legal acts, including pay regulations. The requirement of gender neutrality in job advertisements and job titles may entail the need to adapt these documents.

Experts emphasize that this process may go beyond just changing the name and require a broader analysis of compensation provisions. It is worth taking steps now to understand the upcoming regulations and prepare your organization for these changes.

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