Pay transparency: the regulations will come into force later than originally planned. A new bill is ready.

Comment by Joanna Liksza, MyBenefit expert at Benefit Systems.

The Ministry of Family, Labour and Social Policy has published a new draft law on strengthening the application of the right to equal pay for men and women for equal work or for work of equal value. The new regulations will come into force six months after the act is announced. It is currently in the consultation phase. This means that companies have gained additional time to prepare for the new law, which, in accordance with the provisions of Directive 2023/970, was originally supposed to enter into force on 7 June 2026 at the latest.

The key and most time-consuming stage of preparation for the new regulations is job evaluation. Without this, it is impossible to create transparent remuneration structures or justify pay differences and these are the most important areas introduced by the directive.

According to the proposed regulations, every employer – regardless of the size of the company – will be obliged to assess the value of work in individual positions or, in the absence thereof, types of work. Based on this, companies will classify roles and identify groups of employees performing the same job or work of comparable value.

This assessment should be based on four mandatory criteria: responsibility, skills, effort, and working conditions. Depending on the specific nature of the organisation, it will be possible to refine them through additional sub-criteria or extend them with other assessment elements.

However, it is crucial that all the criteria are used in an objective and gender-neutral manner.

Poland is not the only country that has decided to postpone the implementation of pay transparency regulations. Sweden made such a decision in March this year. It will introduce the regulations on 1 January 2027. The Swedish labour market, which has been operating based on mandatory pay analyses and comparisons of work of the same value for years, in fact forces the use of job evaluation that is partially consistent with the directive’s guidelines. Although for the Swedish market this is an evolution, not a revolution, companies there are also reporting significant operational difficulties. This clearly shows that even mature systems of remuneration evaluation consider the process to be difficult.

Job evaluation will be particularly challenging for employers who undertake this process for the first time. And these constitute approximately 12% of medium-sized and large enterprises in Poland (“Pay Transparency in Poland” report by Grand Thornton).

Despite growing awareness of the upcoming changes, the level of preparation of Polish companies remains limited. One in five organisations indicates that it has no knowledge of remuneration management. Nearly half of the companies report a lack of tools to implement the requirements of the directive. Surveys also indicate that for 61% of organisations, the introduction of tools and methods for job evaluation would be a significant improvement. [1]

The amount of data, the need to update it, and the requirements of reporting and communication with employees mean that the traditional Excel-based approach will quickly cease to be sufficient. HR tools supporting the evaluation process, remuneration analysis, reporting and communication not only allow for the acceleration of the process, but above all ensure its consistency, durability and availability, which will be crucial in the context of new regulations. The first IT solutions in the form of HR tools that help companies in this area, such as the Remuneration Module and Total Reward Statement in the MyBenefit Cafeteria, have already appeared on the market.

To sum up, even if the implementation date in Poland has been postponed, this does not change the essence of the challenge. Companies that start job evaluation now will not only gain time but can also build an advantage – both operational and image-wise. Those that wait may be forced to implement changes in crisis mode.