Pay transparency in HR practice - implementing EU Directive 2023/970 and employee communication
A comprehensive training for HR teams on the practical implementation of EU Directive 2023/970 on pay transparency and the Polish implementing act (draft published 16 December 2025). A unique three-perspective approach combining labor law expertise, HR processes and communication psychology: participants learn the new employer obligations (recruitment from 24 December 2025, full implementation by 7 June 2026), job evaluation principles, gender pay gap reporting methodology and design processes for handling employee information requests. Day two focuses on change communication inside the organization, running difficult conversations with employees and managing emotional reactions during the transparency rollout. The training closes with a practical implementation plan - a roadmap of actions up to 7 June 2026.
Why this training?
EU Directive 2023/970 on pay transparency is the most significant labor law change in years. In Poland, transparency obligations at the recruitment stage have been in force since 24 December 2025, and the directive must be fully implemented by 7 June 2026. The government’s bill, published on 16 December 2025, introduces obligations that many HR departments have never faced: pay gap reporting, job evaluation as the foundation of a pay policy, handling employee requests about average compensation, and new recruitment rules.
But implementation is not just a legal matter. Pay transparency is a cultural shift that triggers emotions across employees, teams and managers. Without a deliberate approach to the change, rollouts can lead to drops in engagement, a wave of difficult conversations and a crisis of trust.
What sets the program apart?
- Three perspectives in one training: labor law, HR processes and communication psychology - a unique, complete view that individual vertical trainings do not deliver.
- Up to date: the program is based on the government’s bill of 16 December 2025 and reflects the state of Polish law in spring 2026.
- Practice, not theory: workshops cover job evaluation, compensation policy design, employee request workflow and simulations of difficult conversations.
- Ready-to-use materials: participants receive templates for compensation policies, request-handling procedures, GDPR clauses and communication templates for employees and candidates.
- Implementation plan: the training ends with a concrete roadmap of actions up to 7 June 2026 for the participant’s organization.
Outcomes for the organization
After the training, the HR team is ready to run the implementation independently: from the entry audit, through job evaluation and pay gap reporting, to communication with employees and candidates. The organization gains a team that can handle difficult conversations, manage emotional reactions and minimize legal and reputational risk. Participants leave with a concrete timeline and assignment of responsibilities - which allows the organization to enter the implementation period with an advantage over its competitors.
Benefits
- Understand the full scope of obligations under Directive 2023/970 and the Polish implementing act
- Master the job evaluation methodology as the foundation for pay equity
- Build procedures for handling employee requests for pay information
- Learn how to conduct gender pay gap reporting
- Draft a compensation policy and communication materials for employees and candidates
- Develop the competence to lead difficult conversations with employees about pay
- Build an organizational implementation plan with a schedule and assignment of responsibilities
Who is this training for?
Prerequisites
- Basic knowledge of HR processes (recruitment, compensation, reviews)
- General awareness of labor law matters
- At least one year of HR experience or a decision-making role related to compensation
Training program
Legal context - EU Directive 2023/970 and the Polish act
- Origin of the regulation and the EU legislator's goals
- Key concepts: work of equal value, pay gap, job evaluation
- Implementation timeline: recruitment stage (from 24 December 2025) and full implementation (by 7 June 2026)
- Scope of application - the broad EU concept of a worker vs the Polish Labor Code
- Differences between current Labor Code provisions and the new requirements
New employer obligations - the map of change
- Information obligations towards candidates (pay ranges in job offers, ban on asking about salary history)
- Obligations towards employees - right to information about average compensation
- Reporting obligations by organization size (100, 150, 250+ employees)
- Documentation and audit trail of pay decisions
- Sanctions for non-compliance - fines, compensation, back pay
Job evaluation as the foundation of pay equity
- Analytical and non-analytical evaluation methods
- Objective and gender-neutral criteria
- Grouping of jobs of equal value
- Pay grids and salary ranges
- Hands-on workshop: evaluating selected roles
Gender pay gap reporting
- Report structure - data required by the act
- Pay gap calculation methodology - mean, median, quartiles
- Polish context: 7.8% gap vs the EU average of 12.7%
- Joint pay assessment - when it becomes mandatory
- Communicating the results inside and outside the organization
Compensation policy - document design
- Structure of a directive-compliant compensation policy
- Pay-setting criteria - objective, neutral, measurable
- Promotion and pay progression paths
- Policy communication - where, how and when
- Workshop: audit of the participant's current pay policy
Employee right to information - procedure and templates
- Scope of information available to employees (level, progression, group averages)
- Handling an employee request - deadlines, format, accountable parties
- Response templates and best practices
- Privacy limits and GDPR in the context of pay transparency
- Workshop: designing a request-handling workflow
Transparency in the recruitment process
- Constructing job postings with pay ranges
- Running the interview without asking about salary history
- Communicating the pay offer - transparency and negotiation
- Onboarding a new employee - what we communicate on day one
- Simulated recruitment conversations
Organizational change communication - implementation psychology
- Kotter's change model in the pay transparency context
- Resistance from employees, managers and executives - diagnosis and response
- Cascading communication: board → managers → employees
- Change communication plan - channels, tools, frequency
- Case study: transparency rollouts in European organizations
Difficult conversations with employees - the psychological perspective
- Money as a taboo topic - why pay conversations trigger emotions
- Typology of employee reactions (surprise, envy, anger, sense of injustice)
- Conversation techniques: active listening, empathic assertiveness, reframing
- Escalation conversations - when an employee challenges their pay
- Simulations of difficult conversations (role play)
GDPR, data protection and confidentiality in a transparent pay system
- Sensitive data vs pay data - the boundaries
- Anonymization and aggregation in reports
- Rights of candidates and employees to information
- Information obligations - clauses to update
- Case: liability for breaching pay data confidentiality
Risk management and sanctions
- Burden of proof in pay discrimination cases
- The role of labor inspection and supervisory bodies
- Financial and reputational sanctions
- Risk mitigation - internal audit, managerial control, training
- Insurance against employee claims
Organizational implementation plan - roadmap to 7 June 2026
- Stocktaking of the current state - entry audit
- Action schedule: evaluation, policy, procedures, communication, training
- Distribution of responsibility: HR, legal, compliance, board, managers
- Implementation success metrics
- Final workshop: drafting an implementation plan for the participant's organization
Delivery Methods
Online
- Convenience of participating from anywhere
- Interactive live sessions with trainer
- Materials available for 30 days
- No travel costs
On-site
- Direct contact with trainer and group
- Intensive hands-on workshops
- Networking with other participants
- Full focus on learning
Frequently asked questions
When does the act come into force?
Labor Code provisions on transparency at the recruitment stage have been in force since 24 December 2025. Full implementation of Directive 2023/970 must take place by 7 June 2026. The Polish government's bill was published on 16 December 2025.
Does transparency mean disclosing individual salaries?
No. Pay transparency means disclosing the employer's compensation policy and giving employees access to information about average pay for people performing work of the same value - not access to specific individual salaries.
Who is subject to the reporting obligations?
Employers with at least 100 staff must produce a pay gap report. Frequency depends on size: 250+ report annually, 150-249 every three years, 100-149 every three years starting in 2031.
What are the prerequisites for participants?
We recommend basic knowledge of HR processes (recruitment, compensation, reviews), general awareness of labor law and at least one year of HR experience or a decision-making role related to compensation.
What is the training format?
The training lasts 2 days (16 hours) and is available online and on-site. It combines expert lectures with workshops (evaluation, workflow, policy) and simulations of difficult conversations. We can customize the schedule to fit your team's needs.
Will I receive a certificate?
Yes - every participant receives an EITT completion certificate and a full set of training materials, including compensation policy templates, HR procedures and communication templates for employees and candidates.
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