The new directive on salary transparency, adopted at the European Union level, arouses a lot of emotion in Poland. On the one hand, it offers hope for the ordering of remuneration rules and the reduction of the wage gap. On the other, it causes concern, interpretive chaos and a sense that “not everything is clear yet.”

And the latter is … true.

As of today, not all elements have been clarified in national regulations, and many obligations require reasonable interpretation and good practice, not panicked reactions.

Participating in a webinar from Elevato with experts from iSecure sorted out some of the chaos and helped dress up doubts into a logical narrative: what will actually change and what is a myth.

1. Facts that are already certain

Fact 1: The key date is December 24, 2025.

Anything beyond this framework remains, for today, in the realm of interpretation or future clarification by the legislature.

Fact 2: “Before the employment relationship is established” is also the time of the offer

The information obligation covers the entire stage prior to signing the contract, including:

• submitting an offer,
• Its negotiation,
• acceptance of the offer by the candidate.

This does not automatically mean that the fork must be in the announcement – but at the latest it must be communicated before the contract is signed.

Fact 3: Forks must be realistic

Salary range:

• must reflect the salary actually offered,
• should be based on objective and neutral criteria (e.g., experience, competence, responsibilities).

The regulations do not specify a maximum spread, but they must be reasonably justifiable in the event of a question or dispute.

2. The most common myths that cause panic

Myth 1: You have to disclose the entire remuneration regulations to every candidate

No.
The obligation applies only to those provisions of the regulations that apply to the position – and at the latest before the offer is made.

There is no obligation:

• sending full regulations to all applicants,
• Automatic transfer of entire documents without asking the candidate.

Myth 2: You have to list all bonuses, rewards and benefits in amounts

No.
The obligation to provide information relates to remuneration as defined in the Labor Code, which is what:

• is standard,
• permanent or regular,
• assigned to the position (e.g., base salary, fixed function allowance, regulatory bonus).

There is no obligation:

• Benefit pricing (medical care, sports card),
• specifying the amounts of discretionary awards, jubilee awards, severance pay or overtime.

Myth 3: Forks must always be given as a range

You can specify:

• salary range, or
• one specific amount (for example, when the budget is rigid and does not provide for differences).

However, it is forbidden to give a single amount when, in practice, differential salaries are allowed – this would be an apparent fulfillment of the obligation.

3 Recruitment in practice – what is allowed and what is not

You can ask about financial expectations

New regulations:

• prohibit questions about historical remuneration,
• do not prohibit questions about salary expectations.

Condition: the question must not serve to circumvent the openness of the fork or lead to offering a salary outside the indicated range without objective justification.

You can differentiate forks by location

It is acceptable to use different ranges for the same position (e.g., Warsaw vs. a smaller province) if:

• The difference is due to objective criteria (cost of living, local market),
• The principles are consistent and defensible.

Gender neutrality applies to the entire ad

Not only the names of the positions, but:

• job descriptions,
• requirements,
• Recruitment communications as a whole.

Can be used:

• dual forms (driver/driver),
• Neutral forms (“accounting person”),
• abbreviations like (f,m,n),
• English-language names – taking into account the provisions on the Polish language.

4 What about current employees?

This is one of the most overlooked but key elements.

Openness rules do not apply only to recruitment.
Current employees:

• Have the right to be informed about remuneration rules,
• can learn about the fork for their position and the criteria for promotion,
• have no right to information about the individual salaries of others.

In addition: an employer cannot prohibit employees from disclosing their own salaries.

Summary

The salary disclosure directive is not a sudden revolution, but a planned direction of change for which organizations still have time to prepare. Although some issues need to be clarified, it is already apparent that consistent rules, clear communication and basing pay decisions on objective criteria will be key. Instead of reacting with uncertainty, it is worth treating the new regulations as an impulse to organize recruitment processes and compensation policies, and to strengthen employer credibility.

Sources

Webinar – Salary disclosure directive – what specifically will it change in recruitment? Webinar with iSecure

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