Benefits and Pay Transparency: Are non-wage benefits included in remuneration?

The implementation of the pay transparency directive radically changes the definition of compensation policy in organizations. If you think pay transparency only applies to basic salary, you have outdated information. EU Directive 2023/970 defines remuneration in a way that includes practically everything an employer provides to an employee: bonuses, benefits, company cars, employee capital plans (PPK), or training. From the perspective of EU law, every sports card or private medical care package is an inseparable component of total compensation. This means that non-wage benefits must be a key part of the transparency strategy, and the fact that as many as 85% of employees are unaware of their value becomes a direct problem for the employer. It is precisely this lack of awareness that creates the greatest HR and reputational risk during preparations for the new legal requirements. 

Pay Transparency is not just about salary. Welcome to the realities of 2026.

EU Directive 2023/970 defines remuneration as basic pay and any other additional or variable components paid by the employer – including benefits, bonuses, in-kind benefits, and any other monetary or non-monetary advantages. Non-wage benefits are included in the total remuneration subject to reporting in the pay gap analysis.

What exactly is remuneration? EU Directive 2023/970 defines remuneration in a way that includes practically everything an employer provides to an employee: bonuses, benefits, company cars, employee capital plans (PPK), and training. The act implementing this document into the Polish legal system (draft UC127) foresees extremely strict deadlines and enormous financial penalties, reaching tens of thousands of zlotys for non-compliance. By June 7, 2026, at the latest, Polish companies must re-systematize their pay scales and guarantee employees the right to full knowledge of their earnings.

This has far-reaching consequences for every HR department. The pay gap must be calculated not only based on basic salary but also taking into account quarterly bonuses, annual bonuses, the value of medical packages, sports cards, company cars, and other benefits.

Imagine an organization where the base salaries of financial analysts (men and women) are identical down to the last zloty. It would seem that we have achieved complete pay equality and fairness. Nothing could be further from the truth. If the company gives men higher bonuses and better work tools, and women greater benefits – there is still a pay gap in light of the directive. The controlling authority does not look solely at the transfer amount on the first day of the month. It looks at the entire capital investment an organization makes in a specific individual in a given position.

Tip: Gather all agreements with external service providers and, starting tomorrow, translate the granted packages into specific numerical values for each position in your company spreadsheet. Without this hard data, you will not be able to conduct any reliable job valuation.

Which non-wage benefits are included in the pay gap report?

For pay gap analysis, we only include those allowances and packages that result directly from the job position held, tenure, or achieved results, absolutely excluding strictly social benefits arising from an employee's life situation.

For pay gap reporting between women and men to make sense, you must adhere to one ironclad rule. Only benefits linked to the position or work performance are included in the pay gap analysis, not those resulting solely from an employee's specific life situation (e.g., emergency aid).

In practice, this means that cafeteria benefit packages, discretionary bonuses, and company cars – all of these must be taken into account when examining pay equality between women and men. The table below breaks down individual types of bonuses in detail and explains their status under European law.

You can see a clear logic here – everything that constitutes a market cost for the employer and a regular gain for the employee is treated as part of remuneration. Only occasional aid and benefits paid due to difficult financial situations or unforeseen events affecting team members are excluded.

The Hidden Costs of Ignorance: Why Employees Don't Appreciate Their Packages?

The vast majority of teams are unaware of the real, zloty-denominated value of their non-wage bonuses, leading them to feel financially undervalued despite the enormous investments made by the organization.

Financial education within Polish corporate structures is simply lacking. Non-wage benefits have become so common that many specialists treat them as free air in the office, rather than a part of their hard-earned compensation. The hard numbers prove this. A Benefit Systems study shows that 85% of employees do not know the real value of their benefits. This is a statistic that should keep every HR director responsible for talent retention awake at night.

Let's look at a concrete, real-life example. Anna, working as a mid-level marketer, earns a gross base salary of 8000 zlotys. If an employee doesn't know that the company pays 300 PLN monthly for their MultiSport card, 250 PLN for medical care, and 120 PLN for group insurance – they won't appreciate these 670 PLN per month (over 8,000 PLN annually) when evaluating the employer's offer.

In the context of pay transparency, this has double significance.

• Firstly, the company already has these investments recorded as costs – it simply doesn't communicate them. It spends millions annually without gaining loyalty points in the eyes of the team.
• Secondly, an employee who doesn't see the value of their package more easily compares themselves to market offers based solely on their basic salary — and concludes they are underpaid.

Imagine Anna's job interview with a new company. A competitor offers her 8500 PLN gross, which is a 500 PLN raise. Anna accepts the offer, convinced she has improved her financial situation. She doesn't consider that the new company doesn't cover medical or sports benefits. From a Total Rewards perspective (net total income), Anna just lost out. And you lost an excellent employee solely due to flawed internal communication.

Cafeteria and Total Rewards Statement (TRS) - a systemic solution to the problem

Cafeteria systems integrated with Total Rewards Statement (TRS) modules automatically aggregate all material and non-material components of compensation, clearly presenting the team with a personalized view of their total annual earnings in currency.

Reports such as the "Compensation Best Practices Report 2024" reveal that as many as 58% of organizations declare preparing TRS reports; however, only 44% of them successfully include non-wage benefits. This is a significant oversight that must be rectified before EU deadlines expire. The solution to this challenge is the integration of modern HR Tech tools. Nais Platform allows for the achievement of one of the most important goals of pay transparency from the benefits perspective: to show the employee the full value of their package — including each benefit, its monthly, and annual value.

How exactly does this mechanism work, and how does Nais connect benefits with Total Rewards communication? The answer lies in two specialized operational segments.

Nais Cafeteria Module

• The employee chooses benefits tailored to their needs from over 30,000 offers across 19 categories. This strikes at the heart of the problem of ineffective static packages.
• Instead of imposing a static package on them, the company gives them a budget and a choice.
• Result: the employee sees the value of the benefit — because they chose it themselves. This, in turn, builds invaluable employee agency and is a natural mechanism for increasing awareness of the package's value.

Total Rewards Statement

• The TRS Module in Nais aggregates data on all benefits — from the Nais platform, payroll systems, and manually entered data — and presents the employee with a personalized view of their complete compensation package.
• Every zloty is visible, categorized, and described. No one has to guess how much their private specialist visit costs.
• This mechanism fulfills the statutory obligation to inform employees about the total value of their compensation.

Forget about manually preparing calculations in Excel for hundreds of specialists, managers, and B2B contractors. Maintaining data consistency with high staff turnover and fluctuating market rates from external providers is physically impossible without automation.

Benefit Audit Before 2026: What to Absolutely Avoid?

A critical mistake in 2026 will be distributing benefits based on subjective preferences and discretionary arrangements with individuals, bypassing objective, job-related criteria in pay gap analysis.

Implementing transparency is a painful process if a company has operated for years based on secret contract addendums. Introducing pay transparency can reveal unexpected inequalities in benefit distribution. The new law absolutely does not tolerate "hidden bonuses" and historical privileges for middle management that stem from entrenched arrangements rather than the actual valuation of a given position's difficulty.

Before the regulations come into full effect, it's worth checking if:

• Women and men have equal access to the same benefits (absence of structural discrimination).
• Employees with different forms of employment (employment contract, B2B) have equal opportunities to access benefits.
• Managers are not accumulating benefits (e.g., a better car, higher cafeteria limits) in a way that exacerbates inequalities.
• Benefit data is accurately reflected in the pay gap analysis - and not just basic salary.

A common problem in the Polish market is B2B contracts in the IT sector, where specialists, on the one hand, negotiate substantial net amounts on invoices without ZUS contributions for the employer, and on the other hand, informally receive a full medical and training package on par with employees on employment contracts. How does this affect the pay gap? Terribly. It distorts the total valuation of a position and puts the employer at a disadvantage during potential lawsuits concerning discrimination based on employment form.

FAQ - Benefits and Pay Transparency in Practice

Below, we have prepared answers to questions most frequently asked by the boards of Polish companies preparing for full pay transparency and reporting under the EU directive.

Does the value of private medical care need to be included in the pay gap report?

Yes - if it is employer-funded and linked to the job position, not solely to an employee's specific situation. According to the letter of the law, the value of medical care as a benefit in kind is included in the total remuneration under the directive. When calculating the pay gap, it must be considered whether all employees in comparable positions have equal access to this benefit of equal value. Translating this into business reality: gender, age, or contract type cannot determine whether an employee receives a higher standard health package.

Does a benefit cafeteria help or hinder pay transparency?

It definitely helps - if configured correctly. As mentioned earlier, a cafeteria with an individual budget per employee (rather than a static package) allows each employee to decide on their benefits and be aware of their value. An HR Tech platform records the chosen package, which facilitates data aggregation for Total Rewards Statement and gap analysis. The only condition protecting the employer from breaking the law: the cafeteria budget must be equal for comparable positions - differences in budget cannot be justified by gender.

How to correctly calculate the value of a company car for the TRS report?

The value of a company car for the purposes of Total Rewards Statement is considered a benefit in kind – typically as a monetary value corresponding to the advantage an employee gains from private use. The law allows for some flexibility here, and in practice, several approaches are used: a percentage of the car's market value annually, the actual value of the employee's income for tax purposes, or the cost of renting a comparable car on the market. The most important guidelines from legal experts indicate that the method should be consistent for all employees receiving the same type of benefit. You cannot apply a different calculation methodology for a sales manager compared to a logistics director.

Summary

Transparency will impact the market regardless of whether your organization is fully prepared for it. To effectively mitigate the risk of penalties and the exodus of your most valuable specialists to competitors, remember the following four rules of conduct.

• Transparency covers everything, without exception. EU law and Polish implementing acts consider not only the base salary but also every monetary, equipment, and medical investment directly related to the job position as remuneration.
• A complete lack of financial education is a deadly threat. The vast majority of employees do not understand the value of their benefits and underestimate the perceived value of their own package compared to market conditions.
• Implementing a Total Rewards view is the only logical step to escape misinformation and feelings of injustice within teams.
• Utilize ready-made ecosystems for calculation automation. Modern HR Tech systems drastically reduce the risk of procedural and analytical errors when estimating the total pay gap across different levels of the organizational structure.

Do you want to show employees the full value of their benefits – in accordance with directive requirements?

The Nais platform combines a benefits cafeteria with a module Total Rewards Statement. Every employee sees what they receive and for how much – in a mobile app, 24/7. Request a demo.

Check out the Nais benefits cafeteria module

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