Wage Transparency: What Will Employees Actually Learn?
As Poland prepares to implement EU Directive 2023/970 by 2027, the long-awaited wage transparency rules will provide workers with salary averages rather than access to their colleagues’ exact,...
As Poland prepares to implement EU Directive 2023/970 by 2027, the long-awaited wage transparency rules will provide workers with salary averages rather than access to their colleagues’ exact, individual earnings.
Table Of Content
Transparency Instead of Full Disclosure
The implementation of Directive 2023/970, which aims to strengthen equal pay for men and women, is frequently mislabeled as full wage “disclosure.” In reality, employees will not gain access to specific salaries but will benefit from increased transparency regarding the criteria used to shape compensation packages.
Data Access and Employee Rights
Once the national legislation enters into force, employers must provide requested salary information and annually remind staff of their right to submit such requests. Furthermore, companies with 100 or more employees must disclose general gender pay gaps, which will be publicly available via a monitoring body, while category-specific data will be shared internally with employees.
Defining Key Compensation Concepts
The law introduces three core concepts: remuneration, pay level, and hourly pay level. These metrics allow employees to compare their earnings against others in their designated job category over the preceding 12-month period.
Hourly Pay Level vs. Hourly Rate
The hourly pay level is calculated as a quotient of the annual pay level and the nominal working time, rather than actual hours worked. This means the figure is not equivalent to an individual’s contractual hourly rate, as it excludes overtime and absences.
Identifying the Gender Pay Gap
Employees can request average salary data for their specific job category, broken down by gender. If the information risks identifying an individual’s salary, the employer must refuse the request and direct the employee to an equality body or trade union, which can analyze the data without revealing specific earnings.
Clarifications and Penalties
Receiving data that falls below the category average does not automatically prove discrimination, as pay differences may be justified by objective factors like performance or competence. Employers who violate these transparency obligations face fines ranging from 2,000 to 60,000 PLN.