Equal pay for women and men is no longer just a slogan—it is becoming a binding legal obligation. A draft bill (UC127) implementing EU Directive 2023/970 has been added to the legislative agenda, which means the regulations are entering the final stages of negotiation. For employers, this is a clear signal: the preparation period is now over.
The new regulations introduce a comprehensive system for monitoring, reporting, and enforcing pay equity—with real financial penalties and a strengthened role for oversight bodies.
What changes does the Equal Pay Act bring?
Although the gender pay gap in Poland (7.8%) is lower than the EU average (12.0%), lawmakers have decided to fully implement European standards. This means new obligations for virtually all employers—regardless of industry.
Key changes include not only salary levels, but also the way they are determined, documented, and communicated to employees.
Job Evaluation and Pay Transparency
One of the cornerstones of the new regulations is the objective evaluation of work. Employers will be required to:
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job evaluations based on neutral criteria (skills, effort, responsibility, working conditions),
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the application of transparent rules for determining compensation and promotions,
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providing employees with information on average wages in their category—broken down by gender.
This means that informal pay decisions and discretionary bonuses without clear criteria become risky.
Payroll Reporting – Who and When?
The new law introduces a requirement for larger employers to report the pay gap:
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Companies with 250 or more employees – annual reporting,
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Companies with 100–249 employees – reporting every 3 years.
Deadlines for the first reports:
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150+ employees – through June 7, 2027,
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100–149 employees – by June 7, 2031.
The data will be published by the Central Statistical Office (GUS), which means the results will be comparable to those of competitors —including in terms of public perception.
Joint Salary Review – When Is It Mandatory?
If, within a given category of employees:
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the wage gap will be at least 5%,
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and the employer fails to provide an objective justification,
It will be necessary to conduct a joint assessment of salaries with the participation of labor unions or employee representatives.
Additionally:
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Corrective actions must be implemented,
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within 6–8 months.
This is no longer an analysis “for the drawer,” but a process subject to oversight.
New enforcement mechanisms—a real risk for companies
The law significantly strengthens the position of employees:
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reversed burden of proof —it is the employer who must prove that there was no discrimination,
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minimum compensation = minimum national wage,
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fines ranging from 3,000 to 50,000 zł,
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The National Labor Inspectorate may represent employees in court.
In practice, this means that failing to prepare the necessary documentation can be very costly.
What should employers do right now?
From NJOB's perspective, proactive measures are key, rather than reacting to an audit or report:
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an audit of compensation structures for gender neutrality,
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fair job evaluation,
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a "dry run" analysis of pay gaps before they are made public,
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review of promotion and bonus policies,
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preparing documentation that substantiates the objective criteria.
Companies that use a mixed model (employment contracts, B2B agreements, and service contracts) are particularly at risk. If the same tasks are performed under different legal bases, the employer will have to prove actual differences in how the work is performed, not just in the form of the contract.
Pay equity isn't an HR project—it's a systemic obligation
The Act on Equal Pay for Women and Men is changing the way organizations think about pay. It is no longer a matter of declarations, but of procedures, data, and evidence.
For employers, this means:
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greater transparency,
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more stringent documentation requirements,
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but also an opportunity to streamline compensation systems and reduce legal risks.
The sooner companies begin their preparations, the lower the financial and reputational risks will be in the coming years.