It aims to combat wage discrimination and close the gender pay gap for equal work. Member States are required to implement its provisions into their national laws by 7.06.2026 at the latest. Although there is still some time left for this, in our view, it is worth starting implementation as early as the beginning of 2025 in order to be adequately prepared for it. This is because, as our observations indicate, companies are realising that they are not adequately prepared and the challenges they face to be compliant are difficult and require a significant time investment. According to our estimates, each company will need between 5 and 7 months to implement the law that will be passed by the Polish legislator to implement Directive 2023/970 2023/970.

Wage gap reporting deadline:

• employers with more than 250 employees: will have to report for 2026 in 2027 and annually thereafter.
• employers with 150 to 249 employees: will report every 3 years – for the first time in June 2027 for 2026.
• employers with 100 to 149 employees: they will have to report for the first time in June 2031 for 2030 and every 3 years thereafter.

New obligations imposed on employers:

• an obligation to inform job applicants of the level of pay
• an obligation to inform current employees of the pay level of employees doing the same job or job of equal value,
• an obligation to report on the gender pay gap.

The range of data that will have to be reported includes such as:

• the gender pay gap,
• the pay gap due to additional components, e.g. bonuses,
• the median of the gap,
• median pay gap including additional components,
• percentage of female and male employees who receive additional components of pay or bonuses,
• the percentage of female and male employees in different pay bands,
• the gender pay gap in different categories, taking into account basic hourly wages

Implementation:

In practice, the organisation’s preparation for implementation should include, as our experience indicates, at least the following steps in order to be able to properly carry out the implementation process:

1. an audit of the structure and level of salaries for all positions.
2. directional decisions on how and for what the organisation wants to reward employees.
3. a work plan for the team and the organisation, including deadlines.
4. implementation of the plan.
5. implementation, including consultation with the social partners (in your case the trade unions), modification of the remuneration regulations and/or the company collective agreement. In certain cases also modification of employment contracts.

Total Rewards Statement:

As an aside, I would signal that, in terms of the time a company will need to implement the above provisions, it matters whether it has already implemented a Total Rewards Statement in the past. Indeed, the Total Rewards Statement can be very helpful in carrying out the above steps and can influence the acceleration of the implementation process.