The exact date of entry into force of domestic regulations on remuneration transparency is still unknown. Nevertheless, in accordance with the Directive:

• These provisions must be implemented by 7 June 2026,
• Employers with 150 or more employees should submit their first reports on the pay gap between male and female employees by 7 June 2027, based on data for calendar year 2026.

Therefore, since larger employers will be expected to submit data on the 2026 pay gap between male and female employees already from 2027 and onwards, remuneration structures should be put in order or reorganised by the end of this year. As the preparations may require time-consuming reviews and changes to structures and internal documentation, it is best not to delay with starting this work. It is worth starting preparations for the implementation of the Directive's requirements soon.

Preparations are currently under way on a government draft bill law to implement the Directive. A special team has been set up for this at the Ministry of Family, Labour and Social Policy and it has already held three meetings, to date. At a recent meeting of the parliamentary subcommittee, a ministry official explained that currently a stage of bilateral meetings is being held between representatives of the ministry and European Commission officials in order to establish the Commission’s expectations regarding the details of the Polish draft bill. It is expected to be ready by the end of 2025.

At the same time, legislative work is taking place in the Sejm (Polish parliament) on a parliamentary bill concerning, among other things, the pay disclosure during recruitment. Given the Ministry’s support for this bill, it is likely to be enacted later this year, ahead of the legislation comprehensively implementing the Directive.