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Gender-neutral job titles and a transparent recruitment process – new responsibilities and challenges for employers

by Katarzyna Kołodziej

5 November 2025

What information about remuneration must an employee disclose at the recruitment stage?

An amendment to the Labour Code comes into force on 24/12/2025. According to Article 183ca employers will be required to inform job applicants about the salary in the offered position. This may be a specific amount indicating the starting salary or a salary range. It is important that remuneration is set using objective and neutral criteria, particularly in terms of gender.

Additionally, when the employer is a party to a collective agreement or has a remuneration policy in place, job applicants will have to be made familiar with the relevant provisions at the recruitment stage.

The employer should provide the above information on paper or electronically in the job vacancy notice, before the interview or, at the latest, before establishing the employment relationship. What is important is that job candidates can participate in negotiations on informed and transparent terms.

Employers, for their part, will not be allowed to ask a job candidate about their pay in the current or previous jobs.

How should an employer formulate gender-neutral job titles?

Moreover, starting from 24/12/2025, the employer will have to make sure that the job vacancy notices and job titles are gender-neutral, and the recruitment process is non-discriminatory.

Gender neutrality in job vacancy notices means that job descriptions, including the expected duties and responsibilities, will have to be formulated without using forms that indicate the job applicant’s gender.

A recommended action resulting from the use of gender-neutral job titles in job vacancy notices will also be to reformulate job titles in work and pay policies and collective agreements.

Directive 2023/970 on equal and transparent pay

The amendment aligns with a broader EU context. The new law introduces certain obligations provided for in the Directive (EU) of the European Parliament and of the Council¹ which aims to:

eliminate the gender pay gap;
strengthen the principle of equal pay for male and female workers for equal work or work of equal value;
eliminate pay discrimination in public and private sectors by improving pay transparency.

EU member states, including Poland, must transpose the Directive by 7 June 2026. The Ministry of Family, Labour and Social Policy is currently working on a comprehensive bill to implement the EU regulations.

Find out more about the EU Directive: EU Pay Transparency Directive »

What does this mean for your business?

Do you want to align your recruitment processes with the upcoming regulatory changes? Are you wondering how to properly introduce gender-neutral job titles? Do you have any other questions? Contact us.

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

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Katarzyna Kołodziej

Attorney at law (Poland), LL.M. (Heidelberg)

Senior Associate

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