All for One Pay Gap Kit | All for One Poland

All for One Pay Gap Kit

Alignment of SAP with requirements of EU directive
on pay equity and transparency

According to the EU Directive on Pay Equity and Transparency, member states are obliged to implement by June 7, 2026 relevant legislation aimed at eliminating wage discrimination based on gender (the so-called pay gap). For Polish employers, this will mean ensuring transparent salary structures, based on precise criteria for valuing work, and allowing employees easy access to a range of salary information, starting from the recruitment stage. In addition, employers with 100 or more employees will make regular reports to the monitoring body, and heavy sanctions are foreseen for unjustified exceeding of the 5% pay gap.

For employers using HR and payroll systems from SAP(SAP HCM/HR, SuccessFactors), this means that the systems need to be prepared in such a way that relevant data can be collected (the first reports for employers with 250 or more employees will be for 2026 data) and then reports can be prepared and sent to the monitoring body and relevant information can be provided to employees.

All for One Poland is supporting its clients in developing an equal pay standard, preparing data to enable ongoing monitoring and reporting of the pay gap, and defining criteria to justify possible exceedance of the 5% limits. We are also working on an add-on to SAP that will allow companies to adapt their SAP HR and payroll systems to meet their reporting obligations in this regard.

Your SAP ready for the legal requirements of the Pay Gap directive

Wage gap reporting requires the implementation of an entire system for collecting and sharing data, organizing and segmenting jobs, and most importantly, valuing work and implementing systems that count the wage gap.

Companies that handle their HR and payroll processes in SAP solutions should prepare their systems for the new reporting requirements as soon as possible. This means making changes at both the technical and business levels. Companies should make sure that HR and payroll data is complete, consistent and ready for presentation in the required format.

For HR and payroll systems from SAP (SAP HCM/HR, SuccessFactors), All for One Poland is preparing an add-on that will support the preparation of the report required by the directive and its submission to the relevant monitoring authority. Our service will include the add-on to SAP HR/SuccessFactors, its implementation and configuration, as well as business consulting to support the company in preparing the parameters and criteria for the report.

June 6, 2023

Directive (EU) 2023/970 on strengthening the application of the principle of equal pay for men and women for equal work or work of equal value through pay transparency and enforcement mechanisms (the so-called Pay Gap Directive) has entered into force.

December 16, 2025

The Ministry of Labour and Social Policy has published a draft law on strengthening the application of the right to equal pay between men and women for equal work or work of equal value (number UC127), implementing the full EU Directive 2023/970. The draft is now awaiting further legislative process, and the final legislation must be implemented by June 7, 2026.

December 24, 2025

An amendment to the Labor Code came into force, which is consistent with part of the Directive’s requirements regarding recruitment rules. The main changes are:
a. openness of salaries for a given position and in a given category of employees – already at the recruitment stage (in the announcement/before the interview/before the employment relationship is established);
b. prohibition of asking candidates about their previous salaries;
c. gender neutrality of job advertisements and recruitment processes.

June 7, 2026

Deadline by which member states are required to enact legislation implementing the requirements of the Directive in national laws.

The gender wage gap is the difference in average wage levels between female and male workers, expressed as a percentage of the average wage level of male workers.

Mandatory pay gap report indicators that companies ≥100 employees will have to publish (aggregated, without personal data):

  1. Gender wage gap and its median
  2. The gender wage gap in the form of a complementary or variable component (e.g., bonuses, premiums) and its median
  3. The percentage of female and male employees receiving supplemental or variable components;
  4. The percentage of female and male employees in each wage quartile;
  5. gender wage gap among employees by category of employees, according to the salary resulting from the employee’s personal classification defined by an hourly or monthly rate and supplementary or variable components.

The monitoring body will be required to make this data available to the public.

According to the Directive, the deadlines for reporting the wage gap to the monitoring body will depend on the size of the workforce:

  • Employers with ≥ 250 employees – first report by June 7, 2027 for 2026, then annually for the previous calendar year;
  • Employers with 150 – 249 employees – first report by June 7, 2027 for 2026, then every 3 years for the previous calendar year;
  • Employers with 100 – 149 employees first report by June 7, 2031 and then every 3 years for the previous calendar year

As of December 24, 2025

Changes in recruitment processes introduced by the amendment to the Labor Code – apply to all employers, regardless of the size of their workforce. At this stage, the regulations do not provide for administrative penalties. However, civil claims are possible.

After June 7, 2026

The draft law provides for fines from PLN 2,000 to PLN 60,000 for violations of duties. The employer or a person acting on his behalf is subject to the sanctions.
A catalog of sanctioned violations (Article 45 of the draft):

  1. Failure to value jobs (failure to value jobs/positions)
  2. Failure to provide the employee with access to the criteria for determining wages
  3. Failure to provide an employee with information upon request
  4. Failure to provide information on salaries (individual and average by gender)
  5. Failure to produce a wage gap report
  6. Failure to provide required information to authorities (CSO, PIP, equality authority)
  7. Failure to conduct a joint evaluation of salaries if the prerequisites are met
  8. Failure to implement countermeasures after unjustified wage gap is detected
  9. Introducing a ban in contracts on employees’ salary disclosure

The draft indicates that valuation and transparency obligations apply to all employers, including the public sector. In contrast, sanctions related to reporting and joint evaluation of wages apply only to companies with at least 100 employees.

Take the first step: Pay Gap Kit Readiness Check

Before wage gap reporting becomes mandatory, it’s a good idea to take the one step that saves the most nerves later on: get your salary counting methodology in order and see if you can compare “apples to apples" in your organization.

All for One offers a short Pay Gap Readiness Check of HR systems from SAP (SAP HCM, SuccessFactors), which combines analysis of bill requirements with payroll practice:

  • Inventory of salary and benefit components: what is “basic salary", what is “supplemental/variable" and what is “other employment benefit".
  • Data readiness for the implementation of the All for One Pay Gap Kit: indication of what data and attributes need to be prepared, completed or standardized (including position/role → category mapping, job value elements, completeness of payroll and benefit components, working hours/FTE, absenteeism, and consistent rules for assigning payments to periods).

Learn more

We invite you to watch the recording of the “Autumn HR Rally” conference, during which the debate on preparing HR processes and SAP HR/SuccessFactors systems for the requirements of the Pay Gap Directive was led by:

  • Witold Wieromiej, HR Management Team Leader, All for One
  • Jolanta Zarzecka-Sawicka, Legal Counsel, Labor Law Team Leader, Grant Thornton
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