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Transparency in recruitment becomes mandatory

​​​by ​​​​Katarzyna Kołodziej

30 June 2025​


On 18/06/2025, the President of Poland signed a law1 introducing new rules for recruitment processes.

 
The law will come into effect six months after its promulgation, i.e. on 24/12/2025. The new legislation requires employers to disclose salary already at the job advertisement stage. Objective? Greater transparency, equality and fairness for all candidates.


TABLE OF CONTENTS​​


Amended Labour Code – what's new for employers?


A new Article 183ca will be inserted into the Labour Code, requiring employers to inform job applicants about the salary in the 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.

The current Labour Code defines the concept of remuneration broadly. It includes all remuneration components, regardless of their name and nature, and other work-related benefits granted to employees in cash or in kind. 

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. 

When and how to communicate information to candidates​​​?

The amended Labour Code identifies three points at which employers should provide information on remuneration and the relevant provisions of the collective agreement or remuneration policy:

1. in the job advertisement;
2. before the job interview – if the employer has not advertised a vacancy and has not communicated the information in the job advertisement;
3. before entering into the employment relationship – if the employer has not fulfilled the above conditions.

The information may be provided in paper or electronic form, at the employer's discretion. However, it is crucial that employers provide this information in advance to ensure that job candidates can negotiate in an informed and transparent manner. 

Gender equality and a ban on questions about salary history


The new legislation goes a step further by mandating gender-neutral language in job advertisements and job titles. The recruitment process must be free from any form of discrimination.

Moreover, employers will not be allowed to ask job candidates about their pay in their current or previous jobs.

EU direction of changes – pay equality and transparency


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 Council2 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?


If you are recruiting or planning to recruit in the near future – be prepared for changes. The new regulations are not just a legal obligation but an opportunity to create a culture of openness and trust.
Do you have questions? Are you wondering how to prepare your HR processes for the new regulations?
You are welcome to contact us.


1 Act of 5/06/2025 amending the Labour Code
2 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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