Words matter – neutral language in employment
The principle of non-discrimination has been in force in Polish labour law for over 20 years. At the same time, there is a noticeable tendency to specify and expand provisions in this area. Soon, on 24 December 2025, the principle of non-discrimination will be reinforced once again – by adding art. 183ca to the Labour Code. The adoption of art. 183ca LC relates to partial implementation of European Parliament and Council (EU) Directive 2023/970[1].
This provision introduces rules on transparency regarding remuneration at the recruitment stage. However, it also stipulates that: The employer shall ensure that job advertisements and job titles are gender-neutral and that the recruitment process is non-discriminatory. We focus in this article on new duties of employers in this regard.
Employers should:
- from 24 December 2025 – use gender-neutral job titles not only in job advertisements, but also in other documents used within the organisation. Gender neutrality in job titles can be understood as not favouring either gender (not using a name that refers to only one gender).
- from 24 December 2025 – use job advertisements formulated in a linguistically neutral manner. This applies not only to job titles themselves, but also to other expressions that may indicate gender. In its guidelines on gender-neutral language, the European Parliament has indicated that gender-neutral language is a general term used to define language that is free of sexism or language that is inclusive or egalitarian. The aim of gender-neutral language is to avoid choosing words that can be interpreted as biased, discriminatory or demeaning because they suggest the superiority of one gender over another.
- ensure that the recruitment process is conducted in a non-discriminatory manner. However, the new provision does not introduce any significant change in this respect, as employers are already required to apply the principle of non-discrimination extensively. In practice, this means not only using non-discriminatory language, but also, among other things, applying criteria that are not related to gender (unless there are justified reasons for doing so, as discussed below). The broader concept of non-discriminatory recruitment materials is also important in this regard. For example, materials that only feature images of people of one gender (e.g. women) and highlight benefits only for people of that gender (e.g. menstrual leave) may be questionable. Of course, the key factor in this regard is not the type of benefits offered by the employer, but the overall message of the advertisement, which should not be exclusionary.
Neutral job titles
So, what job titles should employers use to comply with the new regulations? Given the specific nature of the Polish language, gender neutrality in job titles can be achieved in several ways. For example, this can be done as follows:
|
| Method | Example related to the Polish equivalent of the word ‘accountant’ |
| | adding a feminine form or just the feminine ending | księgowy/księgowa or księgowy/-a |
| | supplementing the job title in a ‘default’ grammatical gender (masculine) with brackets (m/f) or (m/f/n), where ‘m’ stands for male, ‘f’ for female, and ‘n’ for all gender identities that fall outside the binary division | księgowy (m/f) lub księgowy (m/f/n) |
| | use of descriptive form by adding a note indicating all genders | księgowy – any gender |
| | using the so-called ixative (i.e. the letter ‘x’ at the end of a word), allowing the reader to freely adjust the ending of the word depending on the specific gender | księgowx |
| | using the so-called underscore (symbol: ‘_’) allowing the reader to freely adjust the ending of a word depending on the specific gender | księgow_ |
| | using person-based form, which boils down to a descriptive indication of the job position | Person specialising in accounting |
It is not necessary to use the same method for all job titles in the organisation. Certain titles may sound better when using a specific method. An example of this is the position of turner – using the job title ‘turner/lathe operator’ may not be the right choice, as in the current understanding, ‘lathe’ is the name of a machine, not a job title. In this case, it would be more appropriate to indicate in the advertisement, for example, ‘a person specialising in lathe work’ or ‘lathe operator (m/f/n)’. In practice, therefore, the choice of the appropriate method of neutralising job titles will depend on the wording of the given title and the employer's preferences.
In this context, an interesting issue is the use of English job titles, which is particularly popular in global organisations (e.g. ‘Manager’). English job titles are gender neutral. On the other hand, the Polish Language Act stipulates that, in principle, documents relating to labour law should be drawn up in Polish. However, the practical risk associated with using only English job titles (in a situation where the other elements of a given document are in Polish or bilingual) is very low.
Neutral advertisement language
According to the new regulations, not only job titles, but the entire job advertisement should be formulated in a gender-neutral manner. In Polish, adjectives, and in some grammatical contexts also verbs and other parts of speech, are inflected according to gender. For example, the English phrase commonly used in scope of duties ‘You’d be responsible for…’ can be translated as ‘Będziesz odpowiedzialny za…’ if the subject is male, or ‘Będziesz odpowiedzialna za…’ if the subject is female. Therefore, to adapt the entire content of the job advertisement to the requirements of gender neutrality, the employer may, for example, use the following methods:
|
| Method | Example related to the Polish equivalent of the phrase ‘You’d be responsible for…’ |
| | use of both full forms – masculine and feminine – or adding only the feminine ending | Będziesz odpowiedzialny/ odpowiedzialna za … or Będziesz odpowiedzialny/a za … |
| | use of the so-called x-ative (i.e. the letter ‘x’ at the end of a word), allowing the reader to freely adjust the ending of the word depending on the specific gender | Będziesz odpowiedzialnx za … |
| | use of the so-called underscore (symbol: ‘_’) allowing the reader to freely adjust the ending of a word depending on the specific gender | Będziesz odpowiedzialn_ za … |
| | avoidance of direct references and instead making the neutral word ‘person’ the subject of the sentence | Wybrana osoba będzie odpowiedzialna za… (which means: The chosen person will be responsible for …) |
Documents requiring update
Job advertisement templates may be the first to require updating in accordance with the above rules, provided that the terminology used to date does not meet the requirements of linguistic neutrality. This applies both to job titles themselves and the grammatical forms used throughout the advertisement.
Adjustments may also be necessary for any internal documentation of the employer, in particular work and remuneration regulations, as well as other policies or documents used at the workplace (e.g. presenting organisational structures). An update will be necessary in this regard if the job titles used in these documents are not gender neutral.
Finally, employment contract templates may also need to be updated in the same cases. In employment contracts concluded from 24 December 2025, employers should use a uniformly neutral form of job title (e.g. ‘specjalista/-ka’, which means ‘specialist (m/f)’) or adapt the name to the gender of the candidate/employee on a case-by-case basis (and thus using the masculine form (‘specjalista’) when employing a man and the feminine form (‘specjalistka’) when employing a woman).
The issue of possible adjustments to job titles in existing employment contracts seems more problematic. Some employers amend all employment contracts, which should be considered good practice. However, it may be adequate and sufficient to address the issue of gender-neutral job titles in existing employment contracts in a general document (e.g. by adding a new provision to work regulations or issuing a one-off announcement). Such a document may confirm, in particular, that all job titles appearing in existing employment contracts, even if they appear only in the masculine or feminine grammatical form, should be understood as referring to employees of any gender.
Exceptions
In certain situations, there may be exceptions to the statutory principle of non-discrimination. If the nature of work or conditions under which it is rendered means that a particular gender is a genuine and decisive occupational requirement for an employee, an employer recruiting a person of the selected gender must ensure that proportionate adopted measures do not violate the prohibition of discrimination. This can also apply to non-discriminatory language in employment.
In such cases, although rare in practice, targeting job offers exclusively at persons of a specific gender may be justified. This could potentially apply, for example, to a job offer targeted at men for a position involving, to a significant extent, the lifting of weights exceeding weight limits for women.
Summary
The new regulations pose not only legal but also linguistic challenges for employers. For many people, the use of rarely used forms (e.g. ‘kierowczyni’ as the female form of ‘kierowca’, which means ‘driver’) may seem unnatural at first. However, given that language is constantly evolving, the use of such forms is likely to become commonplace in time.
When undertaking work to adapt language to the new requirements of the Labour Code, it is also important to bear in mind other rules that will come into force on 24 December 2025, which essentially concern the transparency of remuneration in the recruitment process.
Natalia Bigdowska
Joanna Dudek
[1] Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023 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.
