Pay transparency after the EU directive: when Excel stops being enough for HR
Poland missed the deadline for implementing the EU pay transparency directive, but the obligations are still coming. For HR departments and managers, this primarily means much more work with payroll data.
In many companies, salaries have for years been scattered across spreadsheets. One file is held by HR, another by the financial controller, and a third by the manager preparing raises. This setup worked as long as no one from outside asked where pay differences came from. The pay transparency directive means the employer will have to answer that question: quickly, using up-to-date data, and in a way that can stand up in court.
The deadline has passed, the obligations remain
Directive 2023/970 was adopted on 10 May 2023 and entered into force on 6 June 2023. Member states had until 7 June 2026 to transpose it into their national law. Poland did not make it in time. Work is still ongoing on the draft act (government work register number: UC127), and its new version was referred for further work (opens in a new tab) on 4 May 2026. The most likely date for the provisions to come into force is the beginning of 2027.
Some of the changes have been in effect since 24 December 2025, however. They were introduced by an earlier amendment to the Labour Code, which transposed into Polish law the part of the directive concerning recruitment. The employer must provide the candidate with the starting salary or its range before employment and may not ask about earnings in the current or previous jobs. According to the HRrebels “Count HR” survey, roughly two-thirds of companies declare full compliance with these changes. Only 2 percent feel fully ready for all the requirements related to pay equality.
What exactly employers are getting on top of everything else
Transparency does not mean a public list of the salaries of specific individuals. The directive concerns pay criteria, salary ranges, aggregate data, and differences between the earnings of women and men. An employee will be able to ask about their own pay level and about the average earnings of women and men doing the same work or work of equal value. Clauses requiring salaries to be kept confidential will also disappear: everyone will be able to say how much they earn.
The biggest change, however, concerns the distribution of risk. In a dispute, it is the employer who must prove that a difference in pay is justified, not the employee who must prove they are being discriminated against. Without organized data and documented criteria, building such a defense is difficult.
The obligation to report the gender pay gap, i.e. the difference between the average earnings of women and men, will apply to companies employing at least 100 people. Under the directive, employers with at least 250 employees report every year, and the first report, for 2026, must be submitted by 7 June 2027. Companies with 150 to 249 employees have the same first deadline, then report every three years. Companies with 100 to 149 employees will join in 2031. Polish commentaries present these thresholds differently, so they will ultimately be determined by the national act.
The directive also introduces a 5 percent threshold. If the gap in a given category of employees reaches it and cannot be justified by objective, gender-neutral criteria, the employer must correct it. Failure to respond within six months triggers a mandatory joint pay assessment with the participation of employee representatives. The amount of penalties is still uncertain: reports on the work on the draft mention amounts of up to PLN 60,000, from PLN 3,000 to PLN 50,000, or from PLN 2,000 to PLN 60,000.
Why the spreadsheet is starting to get in the way
Sapient Insights’ global survey (Annual HR Systems Survey) shows that more than 60 percent of HR teams, including in large organizations, still work in Excel. For occasional overviews, that is enough. The problem begins when data has to be constantly updated, medians and averages calculated for many job categories, gaps compared, and employee questions answered within a set time.
Every export, file copy, manual correction, and sending of a report to yet another person increases the risk of error and of losing control over who has access to the whole company’s salaries. Anna Voit of Benefit Systems, a company that itself sells HR tools—which should be kept in mind while reading—puts it this way:
Payroll data requires a different level of caution than ordinary operational reports. It is not only about regulatory compliance, but also about employee trust and organizational security. That is why it is becoming increasingly important to limit manual file processing and the number of people who come into contact with full databases.
Not every company immediately needs a new system. In our view, a spreadsheet stops being enough when at least one of these conditions is met:
- payroll data comes from several sources and is combined manually,
- more than a few people view the full salary database, and files circulate by email,
- answering an employee’s question about pay levels requires several days of compiling reports,
- the gap has to be calculated for many employee categories, not just for one average.
How much it costs and what can be lost
Vendors of compensation management systems in Poland do not publish price lists; quotes are provided individually. For a general point of reference, one can look at the ERP systems market: small implementations start at several thousand zlotys, while large ones reach several hundred thousand. This is only an analogy, however, not data about payroll tools.
A bigger cost than the license will be organizing the pay structure itself. The Grant Thornton report “Pay transparency in Poland” (opens in a new tab) (survey conducted at the turn of November and December 2025) shows that only 45 percent of medium-sized and large companies have started preparations. Around 12 percent have never carried out job evaluation, and 58 percent fear they will have to rebuild their compensation system from scratch. The most common problems are the lack of clear criteria for raises and bonuses (27 percent), the lack of documented pay bands (18 percent), and difficulty justifying differences in the same positions (18 percent).
On the other side of the equation are penalties, disputes with a reversed burden of proof, and the loss of team trust. Averages say little about a specific company: the unadjusted gap in Poland was about 7–8 percent in 2023, clearly less than the EU’s 13 percent in 2020. At the same time, according to Statistics Poland data, women earn on average PLN 795.53 less than men; in larger companies the difference reaches PLN 1,600, and in finance and insurance PLN 4,722.60. Organized data also shortens the time needed to respond to employees and reduces the risk of errors in reports submitted to Statistics Poland.
Where to start organizing compensation
The starting point is job evaluation and assigning people to levels, because without that it is impossible to compare “the same work.” Next, documented pay bands and criteria for raises and bonuses are needed. For managers, this means the end of pay decisions based solely on intuition: every discretionary raise will require an argument that can be shown.
Only once the structure is organized is it worth applying a tool to it. Joanna Liksza of Benefit Systems points out that automation takes over the tedious collection of data, and HR can focus on analysis and discussion with the business. However, the system will not fix a pay grid that nobody has thought through.
When deciding on specific obligations and sanctions, it is a good idea to consult a labor law attorney, especially once the national act is finally passed.