To whom should wage gap data be reported?
Employers with at least 100 employees will have to collect and report data on the wage gap between female and male workers. Larger employers (with 150 or more employees) are to provide this information initially by 7 June 2027. But, who is to be the recipient of this information?
Even before the employer's management formally approves wage gap figures, it will be necessary to consult with employee representatives on their reliability and share with them the methodology used in their calculation.
Monitoring bodies are to play a key role. Member states, including Poland, are to designate a national public entity (e.g., statistical office) to which employers will send their wage gap indicators. The monitoring bodies will then make the data available, also on a publicly accessible website. National legislation may provide, as a convenience to employers, that some wage gap data be compiled and submitted to the monitoring body by the state based on wage information normally provided by employers to tax or insurance authorities.
However, data on the wage gap in each category of workers will not be made available to the public. These indicators will be provided by the employer to the monitoring body for information, as well as to employees and their representatives. The labour inspectorate and national equality body will also be able to request to receive this information.
Employees, employee representatives, labour inspectorates and equality bodies are also to gain the right to request additional clarification and details of any data provided by employers, including clarification of any gender pay gap. A response is to be provided “within a reasonable period of time”.