Total Rewards Statement 2.0: How to Implement TRS Compliant with the EU Directive Without IT Paralysis?

June 2026 is approaching inevitably. For HR directors, this date marks the end of an era where the Total Rewards Statement (TRS) was just a "nice-to-have" addition to an Employer Branding strategy. With the implementation of EU Directive 2023/970 on pay transparency, TRS stops being a perk and becomes a critical tool for managing legal and reputational risk.

Most companies in Poland today face a dilemma: should they implement massive, expensive payroll systems that "count every penny," or bet on a communication layer that ensures compliance without turning the IT architecture upside down?

In this article, we break down two approaches to TRS in 2026: the "heavy" model (HRIS) and the "agile" model (represented by Nais). We will answer the question of which one will realistically protect your company from claims and employee turnover.

A New Definition of Pay: What Does Directive 2023/970 Change?

In short: According to EU Directive 2023/970, the concept of remuneration consists not only of the basic salary but every element of benefit provided to the employee: bonuses, benefits (monetary and in-kind), allowances, and intangible values like training or well-being packages.

Until now, many organizations tacitly accepted treating benefits as a "nice freebie" that didn't need to be precisely valued. HR departments focused on tax forms (PIT-11), and communication departments on "fruit Thursdays." This dualism is ending right now.

The new regulations force a paradigm shift. TRS no longer answers the question "what do we offer?" but must answer: "what total, measurable value does the employee receive, and can we prove it is fair?".

What Makes Up "Total Rewards" in 2026?

To avoid the pay gap and accusations of discrimination, you must monitor and communicate:

• Cash: Basic salary, bonuses, overtime.
• Hard Benefits: Employee Capital Plans (PPK), insurance, medical care.
• Soft Benefits: Cafeteria systems, vacation subsidies, tickets.
• Development: Training budgets, funded certificates.

As indicated in the Directive of the European Parliament and of the Council (EU) 2023/970, a lack of transparency in these areas will result not only in financial penalties but, above all, in a reversal of the burden of proof in court cases. It will be the employer who must prove that their remuneration system is objective.

Two Worlds of HR Tech: Compliance Heavy vs. Compliance Ready

Analyzing the HR Tech market in 2024-2025, we see a clear division into two philosophies of building TRS. Choosing one will determine the costs and implementation time in your company.

Model 1: TRS as an "Analytical Combine" (Compliance Heavy)

Represented by large HRIS systems and payroll modules (e.g., SAP, Teta, SD Worx).

• Philosophy: "All data must be in one place, calculated to the penny by a single engine."
• Advantage: Total integration of historical and payroll data.
• Disadvantage: Gigantic entry threshold. Requires perfectly organized data, often forces system migration, and engages IT departments for many months.
• For whom: Corporations with IT budgets counted in millions that already have centralized data.

Model 2: TRS as a "Communication Layer" (Compliance Ready)

This is where the Remuneration and Benefits Module – Total Rewards Statement (TRS Nais) is positioned.

• Philosophy: "Data stays where it is safe (with the client); we provide the visual and communication layer."
• Advantage: Fast implementation (weeks, not years), no interference with the sensitive core of payroll systems, GDPR compliance "by design."
• Disadvantage: It is not a payroll calculation system (and isn't meant to be).
• For whom: Most companies in Poland (SME and Enterprise) that must meet the directive's requirements but do not want to implement a new ERP.

Case Study: Why Do HRIS Implementations Take Years?

Imagine a typical situation. A manufacturing company with 1,500 employees uses three different systems: one for HR, another for payroll, and benefits are in Excel.

The Board decides: "We are implementing a huge HRIS system to have TRS."

What happens next?

1. Months 1-3: Pre-implementation analysis. IT is horrified by the data quality.
2. Months 4-9: Data cleansing. The project stalls because no one knows how to value historical benefits.
3. Month 12: The system launches but is so complicated that employees don't use it. TRS is a dry table in a PDF.

Advice: Do not try to solve communication problems (transparency) with accounting tools. If your goal is clear information for the employee about the value of their package, you need a user interface, not a new SQL database.

The Alternative: TRS Nais as "Safety-First" Architecture

TRS in the Nais version was designed the other way around – from the employee's and legal safety perspective, not from the accounting side. It's an approach we call "Compliance Ready."

Key Differentiators of Nais Architecture:

A. Data Security (GDPR & NIS2)

Unlike solutions requiring the transfer of the entire payroll history to the provider's cloud, Nais allows working on distributed data.

• Nais doesn't need to "see" every transfer.
• The module aggregates information about package values, drastically reducing the risk of sensitive data leakage.
• This is crucial in the era of security audits and growing board liability.

B. Flexibility of "Remuneration" Definition

Payroll systems are rigid. If something doesn't have a code in the social security (ZUS) system, it's hard to add. TRS Nais allows for flexible definition of value tiles:

• Do you have a training budget that isn't in the payroll system? You add it.
• Do you want to show the value of company equipment for private use? You add that.
• This approach aligns perfectly with the KPMG report on employer obligations, which suggests a broad approach to defining a benefit.

C. Communication, Not Just Reporting

The EU Directive speaks of the employee's right to information. Incomprehensible information is useless. TRS Nais visualizes data in a way that is digestible for the "average Joe," supporting annual reviews (Performance Reviews) and salary negotiations.

Comparison Table: Nais vs. Traditional HRIS

Data Deep Dive: The Market Is Not Ready

I often hear from HR Managers: "We have time until 2026." This is an illusion. Data shows that Polish companies are technologically underinvested in the area of "soft" HR, which is suddenly becoming a hard legal requirement.

Statistic: According to research by Benefit Systems / MyBenefit, as many as 49% of companies in Poland declare they do not possess tools ready for implementing pay transparency.

What does this mean in practice? Half the market will wake up in 2026 caught off guard, trying to manually generate reports for hundreds of employees. This is a straight path to errors, data leaks (Excel sent by email!), and communication chaos.

Why is this important now?The Gender Pay Gap in Poland still exists, although it is lower than the EU average. However, the problem isn't just the numbers, but the sense of injustice. Employees don't know how much their colleagues earn (and often overestimate these amounts). TRS is the only tool that cuts off gossip at the water cooler by showing hard data: "Here is how much the company invests in you."

What to Avoid?

Implementing TRS in the face of new regulations, companies commit three cardinal errors. Learn from their failures.

1. Over-engineering: Trying to create a system that automatically fetches data from 15 sources in real-time. The result? The project never leaves the testing phase.
   • Advice: Start with static data updated quarterly. A working TRS once a quarter is better than a "perfect" system that never launched.
2. Ignoring Context: Sending an employee a dry calculation: "Your salary is X, benefits Y."
   • Advice: TRS must contain a narrative. Why do we offer such benefits? How does this relate to the market? Nais allows wrapping numbers in appropriate storytelling.
3. Treating TRS as a One-Off: Printing a slip once a year.
   • Advice: Employment value changes dynamically. TRS should be available online 24/7 so the employee can look at it before a raise negotiation.

FAQ: Total Rewards Statement and the Law

What exactly is a Total Rewards Statement (TRS)?It is a personalized document or dashboard that sums up the financial and non-financial value of the employer's investment in the employee. It includes salary, bonuses, benefits, training, and organizational culture.

Does the EU Directive mandate having a TRS?Not directly. The directive mandates transparency and the right of access to information. TRS is not named as an obligation, but it is de facto the best and safest way to fulfill this obligation. The alternative is manually answering employee inquiries, which is unfeasible at a large scale. You can read more about the implementation work on the Ministry of Family, Labour and Social Policy website.

Does TRS in Nais replace Gender Pay Gap reporting?No. GPG reporting is a separate analytical process required for large companies. TRS Nais is a tool for communication with the employee. These two processes are complementary: The GPG report is for the office/board, TRS is for the employee. Dentons writes more extensively about the legal aspects.

Is showing benefits in TRS safe (GDPR)?Yes, if you do it in a secure environment. Sending such data by email in an Excel file is risky. Making it available on a secured platform (like Nais), where the employee logs in individually, is a market standard consistent with security policies.

Will TRS work in a small company (50+ people)?Definitely yes. In smaller companies, the perception of remuneration is often distorted ("the boss pays little") because employees don't see the hidden costs (training, equipment, events). TRS in a SaaS model (like Nais) is cheap to implement and immediately raises the perceived value of the employer's offer.

What to Do Tomorrow Morning?

Don't wait until the last minute (June 2026). The process of building transparency is a cultural change, not just a technological one.

1. Audit remuneration components. List everything you give employees beyond the salary. You will be surprised how long this list is.
2. Separate "Compliance Heavy" from "Compliance Ready". Decide if you need a new payroll system or a communication tool. If the latter – test TRS Nais.
3. Start communicating now. Even if you don't have perfect data yet, start teaching managers to talk about "total value," not just the "net amount in hand."

TRS has stopped being a question of "is it worth it?". It has become a question of "how to do it wisely?". Choosing a lightweight architecture focused on communication and data security is the shortest path to peace of mind for the HR department in the coming turbulent months.

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