New regulations on pay transparency are intended to increase transparency and help eliminate unjustified pay gaps. In practice, however, their interpretation still raises many questions – among both employees and employers.
As Renata Bugiel points out, particular caution is required when analysing information on the average pay of people performing the same work or work of equal value. Simply comparing a specific employee’s pay with the average for a given group does not yet allow for clear conclusions to be drawn regarding possible pay discrimination.
This is because numerous factors can influence pay levels, such as professional experience, scope of responsibility, length of service, qualifications held, or the results achieved by the employee. Consequently, averaged data, devoid of the appropriate context, can lead to erroneous assessments and unnecessary disputes.
Therefore, before making allegations of unequal treatment, it is worth asking the employer for further clarification and justification of the data presented. This allows for a better understanding of the reasons behind any pay differences and reduces the risk of jumping to conclusions.
Prawo.pl provides a more detailed discussion of the practical issues involved in interpreting information on average pay. The article includes comments from our labour law expert, Renata Bugiel: LINK







