One hundred days of pay transparency: it’s time to evaluate job positions.
The provisions of the EU Pay Transparency Directive will enter into force on 7 June 2026. This means that companies have less than 100 days left to adapt to the new regulations. Meanwhile, nearly half of large and medium-sized organisations have not started preparing for the new guidelines yet.¹ Experts point out that companies should act now and conduct a job evaluation process as this step must be taken by all employers. Some organisations will do this for the first time.
Implementing the provisions of the EU Pay Transparency Directive – adopted by the European Parliament in 2023 – means a fundamental change in the approach to pay policies in organisations across the European Union. The new regulations impose specific obligations on employers regarding pay transparency, pay gap reporting and ensuring equal pay for women and men for equal work or work of equal value.
Although the deadline for implementing the regulations into national law is approaching inexorably – there are less than 100 days left until 7 June – many companies in Poland are still at an early stage of preparations or have not started them yet. According to the “2025 TRENDS: Pay Transparency” survey by the Compensation & Benefits Club operating within Lazarski University, 6 2% of companies estimate that in the first quarter of 2026 they will still be in the initial phase of preparations. In turn, the Grand Thornton’s “Pay Transparency in Poland” survey indicates that in the fourth quarter of 2025, nearly half of large and medium-sized companies did not take any action.
Every company will have to take action
The directive will cover all organisations having employees. Some obligations – such as informing candidates about pay at the recruitment stage – are already in force thanks to the amendment to the Labour Code introduced in December 2025. The right of employees to information about pay levels is still ahead of us, but it will also apply to all employers. Larger companies will also be obliged to report the pay gap.
– This is not a change that can be postponed or limited to cosmetic adjustments. We are talking about rebuilding the foundations of pay policy. The preparations should be based on a thorough analysis and arrangement of the organisational structure. The next step is the evaluation of job positions, which the directive provides a specific framework for. This means that even if companies have up-to-date job descriptions, including roles and responsibilities, employers will need to update them to reflect the new guidelines. As a result, every company faces a period of grassroots work in terms of pays, and there is very little of it left. Companies that will approach job evaluation for the first time will face a particularly big challenge and there are about 12% of them in Poland ² – emphasises Joanna Liksza, MyBenefit expert at Benefit Systems and head of the Compensation & Benefits postgraduate studies at Lazarski University.
What are companies waiting for?
72% of organisations indicate that the greatest facilitation in the entire process would be the adoption of national regulations.³ Meanwhile, the draft law is still at the consultation stage.
– The lack of national regulations undoubtedly causes difficulties. Nevertheless, the directive provides us with certain knowledge, for example, regarding criteria that are worth using today when evaluating job positions. These criteria must be included in national regulations – points out Joanna Liksza.
The EU directive introduces four mandatory criteria for job evaluation: skills, responsibility, working conditions and effort.
– Without applying these criteria, it is impossible to meet the key requirement of the directive, i.e. comparing the remuneration of employees performing the same work or work of equal value – points out Joanna Liksza.
Systemic support
Another improvement that 61% of organisations see as facilitating the process of preparing for new requirements is the introduction of tools and methods for job evaluation.
– Therefore, technological solutions supporting transparency are becoming increasingly important. HR Tools solutions are benefits created for HR specialists who face tedious processes, such as preparing for the implementation of pay transparency. One such solution is the MyBenefit Pay Module, which helps aggregate and process information related to job evaluation and provides analytical support, for example, in calculating the pay gap or analysing pay consistency and fairness – says Joanna Liksza.
One thing is certain: every company will have to take active measures. Companies should therefore not wonder when, but how to start the process of adapting to the new requirements.
[1] Grand Thorton “Pay Transparency in Poland”
[2] Grand Thorton “Pay Transparency in Poland”
Agnieszka Bemowska-Niewiarowska
Benefit Systems has been a leader in the Polish non-financial benefits market for over 20 years and one of the most important players in the fitness industry in the region. For years, the company has been setting market development directions, creating modern solutions that support employee wellbeing and promote an active lifestyle. Benefit Systems’ flagship product is the MultiSport Programme – the most recognizable and most frequently chosen sports programme in Poland, providing access to thousands of sports and recreational facilities. The company’s strong portfolio is complemented by the MyBenefit cafeteria platform and the comprehensive Multi.Life wellbeing programme, creating a unique ecosystem of benefits for companies that care about their employees. Benefit Systems is also dynamically expanding its presence abroad. The company’s sports offer is available in the Czech Republic, Slovakia, Bulgaria, Croatia and Turkey, which strengthens its position as one of the key providers of wellbeing services in Central and Eastern Europe. The group is also a major operator of fitness clubs in six markets, and in Poland it is responsible for well-known networks, including Fabryka Formy, FitFabric, Fitness Academy, My Fitness Place and Zdrofit. Benefit Systems’ mission is to inspire physical activity and care for health at every stage of life. That’s why the company runs numerous educational and health-promoting initiatives for children, adults, and seniors, including through the MultiSport Foundation. Its actions confirm that the role of a leader is not only about scale, but also about real social influence. Since 2018, Benefit Systems has been a member of the prestigious B Corp community, which brings together companies that adhere to the highest standards of responsibility and social involvement in their business. More information at benefitsystems.pl/en and biuroprasowe.benefitsystems.pl/releases/English.
