Pay Transparency in Poland. Why pay transparency has become a test of organizational maturity

Key points in brief

• Only 48% of employees believe their company's pay system is transparent, while 74% want greater transparency.
• EU Directive 2023/970 introduces pay ranges in job postings, pay gap reporting, and a reversed burden of proof; in Poland, some of its provisions have already been in force since December 2025.
• Poland’s unadjusted gender pay gap of 7–8% may create a false sense of security - women’s median pay is around 17% lower.
• Levelly.ai’s proprietary Compensation Confidence Index, CCI, stands at 62.9/100 for Poland; transparency is the weakest dimension at 57.7%.

Recommendation: treat the delay in the Polish legislation as a window for preparation: audit, define clear criteria and improve the quality of pay conversations.

Only 48% of employees see the pay system as transparent

The strongest figure in the Levelly.ai report is not about trust. Only 48% of working Poles believe their company's pay system is transparent. At the same time, as many as 74% declare openness to greater transparency. There is a gap between what organizations offer and what employees expect - only one in five employers regularly publishes salary ranges in job postings.

The biggest risk for companies today is not transparency, but the lack of it. For years, pay transparency was treated as a threat to team stability. Levelly.ai’s data points to the opposite relationship. Where employees do not understand pay rules, speculation appears, trust in managers declines, turnover and conflict increase, and the costs of these issues quickly exceed the cost of putting the pay policy in order.

Importantly, employees are not demanding mechanical equality, but rationality in the system: they want to understand why someone received a raise, promotion or bonus.

Poland’s pay gap creates a false sense of security

Poland has one of the lowest unadjusted gender pay gaps in the European Union. According to Eurostat and Statistics Poland, it stands at around 7–8%, compared with the EU average of 12.7% in 2023. This is a figure often quoted at conferences, but the problem is that it measures something different than many assume.

A low unadjusted gap is not proof of equality - it may be proof of segregation. The raw indicator compares the average earnings of all women and all men, without accounting for job role, sector or tenure. In Poland, it is low partly because women are overrepresented in lower-paid sectors - healthcare, education and public administration - and underrepresented in technology and finance. When these factors are taken into account, the actual pay difference for work of equal value is significantly higher. The median gap is telling: women’s median pay in Poland is around 17% lower than men’s. The higher the level in the organizational structure, the greater the inequality. Women account for only 23% of senior management in listed companies.

This is the first reason why transparency is uncomfortable. It exposes the gap between the “average for PR purposes” and the reality of pay ranges in specific roles. The directive's mechanism is brutally specific here: if the pay gap in a given employee category exceeds 5% and the employer cannot objectively justify it, corrective action will be required.

On top of this comes the reversed burden of proof: in pay discrimination disputes, the employer must prove that pay is fair.

Directive 2023/970: what exactly changes for employers

In brief: what is the Pay Transparency Directive?
EU Directive 2023/970 on pay transparency requires employers to disclose pay ranges, either in the job posting or before the interview, prohibits asking candidates about their previous pay, introduces pay gap reporting and shifts the burden of proof to the employer in equal pay disputes.

By 7 June, Member States were supposed to implement Directive 2023/970. They did not. On the deadline date, full provisions were in force in only four countries: Italy, Slovakia, Lithuania and Malta. Poland, whose latest draft bill, UC127 from April 2026, postponed the actual entry into force until 2027, found itself among the many latecomers.

It is easy to treat this as a sigh of relief. That would be a management mistake. Some Polish provisions are already in force: since December 2025, pay ranges must appear in job postings or be provided before the first interview, and asking candidates about previous earnings is prohibited. The market is not waiting for the law.

What the pay gap does not measure - and why it accumulates over a lifetime

The OECD report Gender Equality in a Changing World, published in 2025, takes into account a dimension that a single number cannot capture: time. Inequalities at work are not a single event, but a process that accumulates over decades. Women are less likely to work full-time, more likely to interrupt their careers for caregiving, and more likely to enter lower-valued occupations. Each of these differences may seem minor on its own. Together, they form a trajectory whose endpoint is retirement. In Poland, women’s average pension is more than PLN 1,500 per month lower than men’s.

If inequality could be eliminated by law alone, it would have disappeared long ago - equal pay legislation has existed in Europe for decades. The OECD explains why this is not enough: inequality is “transversal”; it cuts across education, care, promotions, health, and cultural norms simultaneously. That is why the OECD recommends not single interventions, but “policy mixes” - combining a top-down approach, legislation, with a bottom-up one, company practices. The directive is the top. The bottom is the company: real promotion criteria, the quality of pay conversations and a sense of safety.

The CCI Index. Measuring the trust that HR data does not show

In brief: what is the CCI Index?
The Compensation Confidence Index, CCI, is Levelly.ai’s proprietary indicator. It synthesises six dimensions of employee experience -  from fairness and transparency to safety in conversations and the relationship with the manager. For Poland, it stands at 62.9/100.

It is precisely these dimensions - not the gap alone - that determine whether transparency actually works. The weakest link is pay transparency, at 57.7%. Employees do not understand what factors determine pay decisions. Equally telling are the indicators that no regulation measures: psychological safety and the quality of the relationship with the manager. This is exactly the “bottom-up” half that the OECD refers to. In the Levelly.ai study, 42% of employees - and as many as 54% of women - feel discomfort when discussing a raise, and one in three employees has never had such a conversation. Transparency that is not accompanied by a sense of safety remains a façade.

What this means for leaders: three steps for the coming months

The British experience with mandatory gender pay gap reporting is instructive. In 2023, as many as 78% of large employers disclosed a pay gap unfavourable to women, but only 44% presented a remediation plan. Companies that treated transparency purely as an obligation quickly ran into reputational problems. Those that used it to organize pay policy and strengthen managers gained greater cost predictability, higher trust and a stronger competitive position.

The minimum program comes down to three moves:

1. Calculate the truth about your organization. Conduct an audit of the adjusted pay gap and employee perception before reporting forces you to.
2. Build clear criteria into recruitment, promotions and raises - not just job postings. to. The lack of criteria is the main source of frustration for employees.
3. Treat flexible work, equal sharing of care responsibilities and the quality of pay conversations as part of pay policy, not a soft add-on.

A test that cannot be postponed

In the new reality, the advantage will not go to those who pay the most, but to companies that can convincingly answer one simple employee question: “Why this amount?” This question will not disappear just because the legislation is delayed, as awareness of rights is outpacing the law. The deadline has passed, the regulations are slipping, but the test is already underway. A CCI score of 62.9 shows that most Polish companies are still in the middle of this transformation. How leaders respond to this test in the coming months will say more about the maturity of their organizations than many ESG strategies.

About the data and resources

Data on perception, the CCI index of 62.9, discomfort in pay conversations and the British lesson come from the report: Levelly.ai, 2026, Polish Employees on Pay Transparency and Pay Fairness, Experience Institute study, N=1050, January 2026. The framework of “policy mixes” and the logic of accumulating inequalities are drawn from the OECD (2025), Gender Equality in a Changing World. The status of Directive 2023/970 and data on the gender pay gap and pension gap are sourced from Eurostat, Statistics Poland, and the OECD