Pay Transparency: How to Prepare Your Company for New Regulations and Build Trust

Money remains one of the last great taboos in Poland. We discuss politics, religion, and even health issues, but the question "how much do you earn?" still causes consternation. However, Polish entrepreneurs have just been given a deadline that will change this state of affairs—sooner than many assumed.

Much has been said about 2026 as the final EU deadline. Yet, according to the latest information and draft amendments to Polish law, new regulations on pay transparency are set to enter into force as early as December 24, 2025.

This means that this year's holidays may bring Polish companies not only gifts but also a revolution in HR departments. Is your organization ready for it?

In this article, based on expert knowledge from the Nais webinar, we explain exactly what will change in the Polish Labor Code, what pay transparency truly means, and how to use this short time to turn a legal requirement into a business advantage.

What is Pay Transparency? (Definitions and Myths)

Before diving into the regulations, it is worth clarifying definitions, as many myths have arisen around the concept of "pay transparency." For Polish employees and employers, distinguishing between two approaches is key.

Pay transparency, in the context of the upcoming regulations, means the transparency of rules, not necessarily the public disclosure of specific amounts assigned to a name.

• What it is NOT: Transparency does not mean that a payroll list with names and exact transfer amounts will be posted on the company bulletin board in the kitchen (unless the company itself decides on such a radical step).
• What it IS: It is a system where every employee understands why they earn what they earn. It involves a clear salary structure, defined salary ranges (brackets) for specific positions, and a clear path for financial advancement.

In short: The new law eliminates discretion and "secret deals," replacing them with objective criteria.

December 24, 2025 – What Must You Implement Before This Date?

Although Directive (EU) 2023/970 of the European Parliament and of the Council gives member states time, the Polish legislator aims to implement the regulations by December 24, 2025.

Here are the 4 legal pillars that will change the Polish labor market overnight:

1. Revolution in Recruitment (End of Salary History Questions)

This is a change we will feel immediately. From the moment the act enters into force:

• Mandatory Salary Ranges: The employer will be required to inform the candidate about the starting salary or the range (brackets) provided for the given position. This information must be included in the job advertisement or provided before the first job interview at the latest.
• Ban on History Questions: The employer will have no right to ask the candidate how much they earned at their previous employer. Negotiations "based on the payslip from the previous company" are becoming history. What matters are competencies and the position's budget.

2. Employee's Right to Information

From December 24, every employee gains a powerful tool. They will be able to submit a request to the employer for information regarding:

• Their individual salary level.
• The average salary level of employees performing the same work or work of equal value (broken down by gender).

The company will not be able to refuse or dismiss the employee with silence. It will have a strict deadline to provide a precise answer.

3. Pay Gap Reporting

Large organizations will be subject to a reporting obligation. They will have to cyclically report differences in salaries between women and men.

• If the pay gap exceeds 5% and cannot be justified by objective, neutral criteria, the employer will have to conduct a joint pay assessment in cooperation with employee representatives.

4. Equal Pay for Equal Work (Job Evaluation)

This is the foundation of the changes. Employees performing work of equal value must be remunerated equally. To fulfill this, companies must have an objective job evaluation system in place—before the regulations come into force.

Why Do Polish Companies Fear This Date?

The prospect of December 24 causes anxiety in many boardrooms. Why?

Employer concerns:

• Risk of Poaching: Transparent salary ranges make it easier for competitors to poach employees ("I'll give you 200 PLN more than the range at Company X").
• Internal Pay Pressure: "Why are we looking for a new employee for 8,000 PLN when I've been working here for 5 years and make 7,000 PLN?" This is the question managers fear most.
• Communication Chaos: Fear that revealing data will trigger a wave of claims and conflicts within teams.

As noted during the Nais webinar, fear of transparency is a warning sign. If you are afraid to reveal compensation rules to your people, it likely means those rules are unfair, unclear, or... simply non-existent. The new regulations will ruthlessly expose any mess in the "Excel sheets."

Benefits – Why Be Ready Ahead of Time?

Instead of treating December 24 as doomsday, treat it as a deadline to "clean up" the company. Transparency is an opportunity.

1. Building Trust & Engagement

Polish employees are distrustful. Transparency is the strongest proof that the company plays fair. An employee who understands where their salary comes from and what they must do to get a raise is more engaged and looks for a new job less often. At Nais, we believe that clear pay is the highest form of employee appreciation.

2. More Effective Recruitment

Salary ranges in ads save time and money. You don't waste hours interviewing candidates whose expectations are outside your budget. Moreover, transparent companies are perceived as more attractive employers (better Employer Branding).

3. End of the Pay Gap

Transparency forces equality. When rules are clear, the space for pay discrimination—whether conscious or unconscious—disappears.

How to Prepare Your Company for December 24? Action Plan

There is little time left. Implementing transparency is a process, not a one-time decision. Here is what you need to do in the coming months:

Step 1: Audit and Data Cleanup

Check your HR and payroll systems. Do job titles correspond to what people actually do? Does a "Sales Specialist" in Department A do the same thing as one in Department B? Without organized data, you won't take the next step.

Step 2: Job Evaluation

This is the key to success. You must evaluate every position based on objective criteria (competencies, responsibility, effort). This allows you to determine which roles have "equal value" and should be in the same salary bracket.

Step 3: Building Salary Grid and Ranges

Create pay ranges (min – mid – max) for every position level. Compare current employee earnings with the new grid.

• Note: If you discover inequalities (e.g., new hires earning more than veterans), you must plan a budget to level them out. It is better to do this yourself now than to be forced by a labor court in 2026.

Step 4: Manager Education

Managers, not HR, will be on the front line after December 24. You must teach them how to talk about money, explain salary ranges, and justify pay decisions. Without this, transparency will turn into conflict.

FAQ – Key Questions from Entrepreneurs

Where does the December 24, 2025 date come from? The directive says 2026.The June 2026 date is the final deadline for EU member states. However, Poland plans to implement the regulations earlier as part of the work on the Labor Code amendment. Labor law experts point to December 24, 2025, as the entry date for key changes. You should be ready for this earlier deadline.

Do I have to reveal a specific employee's earnings?No. The regulations speak of sharing average salaries for a given position, broken down by gender. The individual salary of "Jan Kowalski" remains protected unless he decides to reveal it himself.

Can I still use pay confidentiality clauses in contracts?From the moment the regulations enter into force—no. Clauses prohibiting employees from disclosing their own salary amount will become invalid by law.

What if I don't make it by December?You expose yourself to the risk of employee lawsuits for compensation due to unequal treatment and to chaos in recruitment processes, which must comply with the new law.

Summary: Don't Wait for "Christmas"

The date of December 24, 2025, is the final "wake-up call" for Polish HR departments and boards. Pay transparency stops being a matter of choice or goodwill—it becomes hard law.

You can wait until the last minute, risking an image and legal crisis, or start acting today. Organizing the salary grid and building a culture based on openness is an investment that will pay off in employee trust. And at Nais, we know that trust is the most valuable currency in business.

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