Pay transparency is no longer a voluntary element of a freely designed HR policy – it is becoming a binding legal obligation. These changes are introduced by Directive (EU) 2023/970 of the European Parliament and of the Council, the objective of which is to strengthen to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms.
The Directive must be transposed into the Polish legal framework. Accordingly, a second draft of the Polish Act implementing the Directive was published on the website of the Government Legislation Centre in May 2026.
Compared to earlier versions, the draft Act further unifies key concepts and enforcement mechanisms, including the definition of pay structures, the detailed process of joint pay assessment, extends (in relation to initial proposals) certain implementation deadlines, and introduces a national equality body responsible for monitoring and supporting the application of the principle of equal pay.
Under the draft Act, the provisions will enter into force six months after publication, leaving organisations with limited time to prepare for the new requirements – in terms of data, HR systems and internal communication.
The new regulations affect the way organisations:
- design pay systems,
- carry out job evaluation,
- communicate pay principles and gender pay gaps to employees,
- cooperate with trade unions and employee representatives.
Our team provides comprehensive, practical support in adapting these areas, offering clear rationale and solutions aligned with business realities.
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Who is subject to the new pay transparency obligations?
The obligations, which apply to all employers, are of a continuous nature and require not only the preparation of appropriate documentation but, above all, the alignment of HR systems, remuneration policies and internal communication frameworks.
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Which companies require support?
In particular, companies that do not have a clearly defined organisational structure, lack a formal job evaluation framework, do not operate with clearly established grading structures, and base remuneration decisions on historical practices or discretionary judgments.
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What are the benefits of our support?
You will align your remuneration framework with the requirements of the EU Directive and Polish regulations, establish a coherent and logically structured pay model, and minimise the risk of disputes and regulatory scrutiny. Most importantly, you will enhance employee trust and ensure greater predictability and transparency of remuneration practices.
Who is covered by the new obligations and from when?
Obligations applicable to all employers
Regardless of organisational size, the draft Act implementing Directive (EU) 2023/970 requires employers to adopt an active and systematic approach to pay. This includes in particular:
- applying objective, transparent and gender‑neutral criteria for pay-setting and job evaluation,
- developing and applying a consistent job evaluation model enabling comparison of work of equal value,
- agreeing job evaluation criteria with trade unions operating at the workplace,
- agreeing corrective action plan aimed at eliminating the gender pay gap (discrepancies) with trade unions or employee representatives,
- maintaining pay structures that enable pay comparison, such as grading groups or workers categories,
- actively informing employees and their representatives about:
- job evaluation criteria and results,
- the employer’s pay structure,
- pay progression (for employers with more than 50 employees),
- ensuring employees’ right to obtain, upon request, information including average pay levels for comparable categories of workers, broken down by sex,
- ensuring transparent pay progression rules communicated internally within the organisation.
These obligations are continuous in nature and require not only documentation updates, but above all adjustments to HR systems, pay principles and internal communication practices.
Additional obligations for employers subject to reporting requirements
Employers with 100 or more employees will be subject to reporting obligations, including:
- preparing reports on the gender pay gap between men and women,
- submitting data within defined scopes and reporting cycles,
- implementing and agreeing corrective measures where reports reveal unjustified pay differences of material significance.
A properly prepared gender pay gap report also constitutes an important management tool. It provides management with reliable insight into actual (paid) remuneration structures, enables informed identification and elimination of pay inequalities, supports pay and development decisions, and helps build the employer’s image as a transparent and responsible organisation.
When is it worth seeking support?
Our support is particularly relevant for organisations that:
- lack a clearly defined organisational structure (job architecture, task/authority/responsibility descriptions),
- do not have a formal job evaluation framework,
- lack clearly defined workers categories,
- base pay decisions on historical or discretionary practices,
- are not prepared to handle employee requests for pay information,
- identify challenges in justifying pay differences within the organisation,
- cooperate with trade unions and are required to agree evaluation criteria and corrective measures.
The new regulations strengthen employees’ positions and increase employers’ exposure to legal and reputational risks, while significantly increasing the operational burden on HR functions. Effective preparation prior to the Act’s entry into force allows these risks to be substantially mitigated and reduces internal tensions inevitably associated with such a sensitive and emotional topic as pay.
What can be gained from implementing pay transparency?
Through our services, organisations:
- align their pay systems with EU Directive and Polish legal requirements,
- gain a coherent, logical and defensible pay model,
- minimise the risk of disputes, inspections and ad‑hoc pay corrections,
- obtain structured arguments for dialogue with employees and their representatives,
- strengthen trust and predictability of pay principles.
Pay transparency becomes a tool for organisational order – clear and understandable pay rules enhance motivation and retention, which in the long term reduces operational costs and increases organisational effectiveness.
Scope of support
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Pay structure analysis and gender pay gap diagnosis
At this stage, we diagnose the gender pay gap in accordance with applicable regulations, taking into account the Polish transposition of the EU Directive, including statutory and implementing provisions.
We analyse pay data, structure and describe pay components, and classify them into categories (e.g. basic, supplementary, variable) according to their actual purpose and function within the organisation’s pay framework.
Based on proposed Polish implementing rules and current interpretations, we apply the appropriate methodology for calculating the gender pay gap, build and calculate required indicators, and identify gaps, inconsistencies, atypical cases and areas of increased risk.
The outcome is a gender pay gap diagnostic report serving as a reference point for further corrective actions, along with structured datasets and calculation tools enabling cyclical monitoring of the pay gap for any reporting period.
This stage is particularly important not only for Polish employers, but also for organisations with foreign capital, including subsidiaries of international groups, where alignment with local regulations and identification of cross‑country differences is critical.
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Job evaluation
We design and implement a job evaluation model forming the foundation of the pay transparency framework, including:
- development of a job evaluation methodology compliant with the Directive (objectivity, gender neutrality, comparability),
- definition of evaluation criteria (including those required by law),
- development of analytical sub‑criteria reflecting organisational specifics and the business model,
- creation of an analytical point‑factor evaluation method (weights and point values for defined levels).
Together with the Client’s team, we conduct job evaluation to determine which roles contribute the same or equal value to the organisation. The model and results serve as the basis for grading structures, pay ranges, pay progression and transparent communication of remuneration levels.
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Designing pay structures and corrective measures
Based on job evaluation results, we design:
- grading groups,
- pay structures,
- pay ranges,
- pay progression rules,
- corrective action plans aimed at reducing the gender pay gap.
These elements jointly form a coherent and logical pay framework enabling long‑term, value‑based pay policy aligned with organisational strategy and business needs. Such solutions are clear to employees, feasible to agree with their representatives, easy to communicate internally and embed in internal documentation, significantly increasing their durability and acceptance.
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HR report and document templates
As part of the service, the Client receives a toolkit enabling independent and ongoing application of pay transparency principles, including:
- gender pay gap report templates,
- calculation and monitoring spreadsheets,
- job evaluation worksheets used in the point‑factor method,
- job description templates aligned with the adopted evaluation model,
- response templates for employee pay information requests,
- documents supporting internal communication of pay principles and structures.
As a result, the Client gains ready‑to‑use, coherent solutions enabling consistent pay management, efficient fulfilment of information and reporting obligations, and sustainable pay transparency in an orderly, understandable and defensible manner.
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Review of compliance of internal principles, systems and regulations with the Directive / Act
We analyse pay regulations, HR procedures and other HR documentation in terms of their coherence, internal logic and alignment with the organisation’s pay management model. The review covers both business and formal perspectives, with particular focus on the extent to which existing principles and guidelines provide clear and consistent decision‑making frameworks for remuneration.
Where required, Grant Thornton’s employment law team may additionally conduct a legal review and recommend adjustments to internal regulations and HR documentation to support statutory compliance and operational usability.
The outcome is structured and coherent organisational documentation that not only organises pay principles, but above all effectively supports pay decisions, their justification and communication to employees.
Why Grant Thornton?
We provide comprehensive support – from data analysis, through the design and adaptation of HR systems and pay principles, to implementation and effective internal communication. Our solutions are always tailored to the organisation’s business specifics, structure and culture. We work in a practical, partnership‑based manner, delivering concrete, ready‑to‑use solutions that we validate and refine together with the client.
In doing so, we bridge regulatory requirements with business realities, strengthening organisational maturity and the ability to adapt efficiently to evolving regulations and market expectations.
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30+
years in Poland
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1200+
employees in 7 offices
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2500+
clients