By 7 June 2026, European Union Member States must implement Directive (EU) 2023/970 on equal pay for women and men and transparency in pay practices. Although the Polish implementing legislation is still being drafted, the direction of the changes is already clearly defined – and it is worth starting some of the measures in advance.
The new regulations are not limited solely to the prohibition of pay discrimination. In practice, they mean that organisations must streamline their pay systems and prepare them for greater transparency.
Key change: the obligation to streamline remuneration structures
The most important element of the upcoming regulations will be the requirement to base pay on objective and gender-neutral criteria relating to the value of work.
The Directive sets out the minimum criteria that should be taken into account when determining pay:
In practice, this means there is a need to create or update internal pay structures and job evaluation methods. It is these structures that will form the basis for further obligations arising from the new regulations.
Greater pay transparency within the organisation
The Directive also introduces new information obligations towards employees. Employers will be required to provide access to the criteria used in determining:
In practice, this means that employers will need to prepare or update pay policies, regulations or other internal documents describing the principles of pay determination.
Employees will also gain the right to request information regarding their pay in comparison to others performing the same work or work of the same value.
Reporting obligations for larger employers
Larger organisations will also face obligations to report on the gender pay gap. In certain situations, it will also be necessary to conduct a joint pay analysis involving employee representatives and to implement corrective measures.
Although the specific details will be clarified in national legislation, the scope of future obligations can already be anticipated today.
Why it is worth preparing in advance
Experience with other compliance regulations shows that implementing new HR obligations takes time – especially where it is necessary to reorganise pay structures or create new internal policies.
It is already worth verifying whether the solutions used within the organisation:
Early preparation helps avoid time pressure once the regulations implementing the directive come into force.
In practice, adapting the organisation to the new requirements will necessitate not only changes to HR policies, but also an assessment of the compliance of existing pay structures with labour law and the principle of equal pay.
If your organisation is planning to review its remuneration system or prepare policies compliant with Directive 2023/970, it is advisable to begin these activities at this stage of the legislative process, in particular by auditing existing internal regulations and the organisation’s remuneration practices.
Author: Aleksandra Gebuza
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