Pay transparency on the horizon: how companies can make smart use of the time before the new regulations come into force.

The EU Pay Transparency Directive was created to systematise and effectively support this objective. However, this is a complex process that requires a significant amount of work from HR teams. The fact that most EU member states failed to implement the new regulations by the originally scheduled deadline best illustrates just how time-consuming and demanding a challenge this is.

The situation is no different in Poland. Although the regulations were scheduled to take effect on 7 June 2026, the relevant act will likely be incorporated into the Polish legal system in early 2027. Although the legislator has granted entrepreneurs extra time to prepare for these changes, this should not be viewed as a kind of regulatory holiday. It is worth using this period for so-called active waiting and for adjusting internal organisational processes to ensure the smooth implementation of clear and transparent remuneration policies.

– In our experience, some business circles felt a certain sense of relief upon hearing that the deadline for transposing the directive into the Polish legal system had been postponed. While hasty, ad-hoc actions taken under stress could indeed lead to errors, excessive calmness is likewise ill-advised. HR departments play a crucial role here. Their task is to demonstrate to management that this extra time buffer should be used to structure internal processes, familiarise the organisation with them, and properly prepare the management team. This ensures that when the new employee-related obligations come into force in a few months, unnecessary stress can be avoided – comments Joanna Liksza, MyBenefit expert at Benefit Systems and head of the Compensation & Benefits postgraduate programme at Lazarski University.

Currently, approximately 2% of organisations are ready to adopt the new regulations,^[2] whereas as many as half of medium-sized and large companies have not yet begun preparations for this process.^[3] These statistics show that the new law poses a challenge for the business community. According to Benefit Systems experts, aligning HR procedures with the new reality is simply an operational challenge for the new regulations are not just about recalculating employee salaries, but about changing the way the organisation operates.

– Employers will be required to prove that pay differences are based on objective and gender-neutral criteria, rather than being dictated by personal preferences and relationships. In mature organisations, reviews of recruitment, hiring, and job reclassification processes to identify and eliminate any irregularities are already underway. For instance, the volume of applications received in response to job postings is analysed by gender to determine whether the ads are gender-neutral and appeal equally to women and men. Subsequently, the percentage of hired candidates – those selected by managers – is examined to verify the absence of conscious or unconscious cognitive biases – explains Joanna Liksza.

Now is the time for organisations to prepare for the implementation of pay transparency: to develop a coherent structure of roles and positions, organise pay components, analyse the reasons behind pay disparities, and define criteria for awarding pay and salary increases. Consequently, they will be required to analyse the processes as well as HR and payroll documentation. They will also have to remove provisions regarding salary confidentiality and discretionary bonuses from employment contracts, and to prepare amendments to work and remuneration regulations. It is also the time to conduct a thorough job evaluation and implement periodic compensation reviews. Preliminary pay gap audits can already begin to ensure a smooth transition to reporting.

– There are a great many indicators, and it comes as no surprise to us that companies have certain concerns. Organisations that are gradually preparing to implement the directive’s requirements often opt to collect and analyse data using spreadsheets they are already familiar with. However, our experience working with entrepreneurs points to the long-term inefficiency of this solution. There are many challenges, ranging from mundane technical aspects, such as the smooth handling of spreadsheets or the sheer ease of working with hundreds or even thousands of records, to the effective analysis and protection of sensitive employee data. Recognising this challenge, we built the Compensation Module within the MyBenefit cafeteria platform. It effectively supports employers in preparing their organisations for pay transparency. Using our tool, clients are already evaluating job roles based on a methodology fully compliant with the Pay Transparency Directive and the draft national legislation, as well as creating pay structures and analysing compensation. We plan to release the pay gap report template in September so that preparations for reporting can begin. Our clients use the summer break to organise job roles and pay components, ensuring they are ready for pay gap testing in the autumn ​ – comments Joanna Liksza.

Does the introduction of pay transparency mean that all employees will earn the same amount or know their teammates’ salaries? The answer to these two questions is emphatically no. The Pay Transparency Directive is about establishing effective and fair pay systems that boost employee motivation and organisational competitiveness, rather than simply about the disclosure of pay. The new regulations are intended to contribute to the creation of modern organisations that reward employees for their competencies and performance. Therefore, if an employee wishes to compare their remuneration with that of employees in the same category and check whether they are being discriminated against, HR teams must be prepared to provide an answer in accordance with the new regulations. Thanks to a job evaluation mechanism and clear criteria for remuneration and pay increases, the response will be objective. For instance, pay differences will stem from the level of responsibility and skills required for a given position, as well as the competencies and performance of the employees.

The extended timeframe for implementing the regulations offers management boards an opportunity not only to align their companies with the new rules but also to boost their organisations’ competitiveness. An economic transformation process is underway in our country. Poland is ceasing to be a supplier of cheap labour. Our companies need to move to the next level, enhance their attractiveness, and learn to make greater use of technology and data in managing their organisations. Remuneration systems are a tool in the hands of employers for achieving this goal. There is a need to improve employee competencies and performance. Thanks to effective compensation solutions, companies attract, retain, and motivate talent to achieve business goals. The system must be transparent and fair for people to trust it. In this way, management boards build an engaging and competitive work environment, and organisations achieve success.

^{[1] Ipsos Report, INTERNATIONAL WOMEN’S DAY 2026, p. 38}

^{[2] “Wyboista droga do przejrzystości i równości płac”}

^{[3] The Pay Transparency Directive enters into force on 7 June 2026. There are less than 100 days left to comply with the new regulations.}

Agnieszka Bemowska-Niewiarowska

Kierownik Zespołu PR, Benefit Systems

• a.bemowska@benefitsystems.pl
• 517 172 559

^{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.}