Gender pay gap reporting is set to become one of the key obligations for many employers across the EU. The new pay transparency rules stem from Directive (EU) 2023/970 of the European Parliament and of the Council, which aims to secure equal pay for women and men who perform the same work or work of equal value. Below we explain who must report the gender pay gap and from when, what data you need to prepare, and how to get your organisation ready for the new rules.

The new regulations do not require equal pay for all employees. What they do require is that any pay differences result from objective, gender-neutral criteria – such as experience, scope of duties, responsibility or qualifications – rather than from an employee’s gender.

Who will have to report the gender pay gap?

The reporting obligation will depend on headcount:

• 250 or more employees – annual reporting, from 7 June 2027.
• 150–249 employees – reporting every three years, starting in 2027.
• 100–149 employees – first report in 2031, then every three years.
• Smaller companies – reporting on a voluntary basis or under national rules.

Reports will be submitted electronically, via a system being developed by the national statistical authority (in Poland, GUS – Statistics Poland).

What data must the pay gap report include?

Employers will be required to disclose, among others:

• the gender pay gap between women and men,
• the median pay,
• the proportion of women and men in each pay band,
• pay differences across employee groups.

The analysis covers not only base salaries but also bonuses, allowances, awards and other variable pay components.

When is a joint pay assessment required?

A particularly significant obligation will be conducting a joint pay assessment together with employee representatives.

It will be required whenever a gender pay gap of at least 5% is identified in any group of employees performing work of equal value, and the employer cannot demonstrate that the difference results from objective factors. In that case, the employer must also implement remedial measures.

How is the gender pay gap calculated?

The calculation is based on comparing the average pay of women and men – on both an annual and an hourly basis.

All pay components funded by the employer are included, such as bonuses, allowances and awards. Benefits paid by the social security institution (in Poland, ZUS) – such as sick pay or maternity benefits – are not included in the calculation.

Penalties for non-compliance

The draft legislation provides for penalties for, among others:

• failure to prepare the report,
• failure to provide the required information,
• refusing to give employees pay information,
• failure to carry out the required pay assessment,
• failure to implement remedial measures.

Fines set out in the draft law range from several thousand to several tens of thousands of Polish złoty (the exact range depends on the final version of the act – see editorial note).

How to prepare your company for pay gap reporting

Although the first reporting obligations only arrive in 2027, it pays to start preparing well in advance.

Employers should:

• review their pay policy,
• develop transparent job-evaluation criteria,
• ensure the quality of their HR and payroll data.

Early preparation reduces the risk of non-compliance and streamlines the reporting process.

Pay transparency is becoming one of the cornerstones of modern human-resources management. For many organisations it is not only a legal obligation but also an opportunity to build employee trust and strengthen the employer brand.

Get your company ready for pay gap reporting with easybooks

Reliable HR and payroll data is the foundation of compliance with EU Directive 2023/970. easybooks provides comprehensive HR, payroll and accounting services that get your company ready for the new obligations – from organising your data and evaluating jobs, to smooth gender pay gap reporting.

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Frequently Asked Questions (FAQ)

When does gender pay gap reporting start? The largest companies (250+ employees) are expected to file their first reports from 2027, on an annual basis. Smaller employers report less frequently and on later deadlines.

Does the directive require equal pay for everyone? No. It requires that pay differences result from objective, gender-neutral criteria rather than from an employee’s gender.

When is a joint pay assessment needed? When the pay gap in a given employee group is at least 5% and cannot be justified by objective criteria.