Job ads and pay transparency: what to include
The EU pay transparency directive brings pay into the recruiting process: applicants should learn the pay or its range, and employers must not ask about their previous pay. This guide explains what that means for your job ads, what Poland and Germany have in their laws and how to write ads that are clear and inclusive.
The rules in brief
Article 5 of the Pay Transparency Directive (EU) 2023/970 covers the time before employment. Applicants have the right to receive information about the initial pay or its range, based on objective, gender-neutral criteria, and, where applicable, about the relevant provisions of the collective agreement. The information has to allow an informed and transparent negotiation, for example in the published job ad, before the interview or otherwise. Member States had to bring their laws into force by 7 June 2026 (Article 34).
Poland added art. 18³ᶜᵃ to the Labour Code with the act of 4 June 2025 (Dz.U. 2025 item 807). The act was published on 23 June 2025 and, according to its Article 2, entered into force six months after publication; eli.gov.pl gives 24 December 2025 as the date.
Germany: § 11 of the General Equal Treatment Act (AGG) says that a job must not be advertised in breach of the ban on discrimination in § 7(1). § 1 lists the grounds: race or ethnic origin, sex, religion or belief, disability, age and sexual identity. A German law that transposes Directive (EU) 2023/970 was not found on gesetze-im-internet.de as of 30 October 2026. The Pay Transparency Act (EntgTranspG) shown there was last amended in 2021 and has no section on applicants.
Pay information: amount or range
The directive and the Polish rule ask for the initial pay or a range. In Poland, the employer also names the relevant provisions of a collective agreement or of the pay regulations, if they apply. The information comes on paper or electronically and early enough to read it (art. 18³ᶜᵃ § 1 and 2). The order is: in the job ad; if not there, before the interview; otherwise before the employment starts.
- Give a lower and an upper value, the currency and the period: per month, year or hour.
- Say whether the amount is gross or net and for how many working hours.
- Name the objective criteria the range depends on, such as experience or responsibility.
- If a collective agreement applies, name it and the pay group.
- Do not rely on ‘competitive salary’ alone. It gives no information.
Example: ‘Pay: 3,400 to 3,900 € gross per month for 40 hours a week, depending on experience.’ The figures are example values.
No questions about pay history
Article 5(2): the employer must not ask applicants about their pay in their current or previous jobs. In Poland, art. 22¹ § 1 point 6 of the Labour Code now excludes information about pay in current and previous jobs from the work history that an employer requests from applicants. Check your application forms, the fields of your applicant system and your interview guides. The texts we read only cover pay history; a question about the pay someone expects is not named there.
Gender-neutral job titles
Article 5(3) of the directive and art. 18³ᶜᵃ § 3 in Poland: job ads and job titles are gender-neutral, and recruitment is non-discriminatory. In Germany, sex is one of the grounds in § 1 AGG, and § 11 AGG applies to the whole ad.
- In English, use neutral terms: ‘salesperson’ instead of ‘salesman’, ‘chair’ instead of ‘chairman’.
- In German ads, a neutral term, both forms or an addition such as (m/w/d) are common.
- In Polish ads, both forms or an addition such as (k/m) are common.
Inclusive wording in the ad
Look at the whole text, not only the title. Some words exclude people without saying so.
- Age: ‘young, dynamic team’ or ‘max. 35 years’. Describe the team and the work instead.
- Language and origin: ‘native speaker’. Name the level you need, such as ‘very good English (C1)’.
- Gender: ‘the ideal candidate … he’. Address the reader directly with ‘you’.
- Personal data: photo, marital status, family plans. Ask only for what the job requires.
- Requirements: list what the job really needs and mark what is only nice to have.
The parts of a clear job ad
A clear structure helps applicants find the pay and the requirements quickly. A common order:
Before you publish, read the ad once as a person who does not know your company: is the pay easy to find, and would anyone feel excluded?
Work with Do4U
Job ad check takes the text of an ad or the address of its page. The code finds the job title and its form, pay information (amount or range, currency, period, gross or net), questions about previous pay, the structure (tasks, requirements, offer, application, contact) and the length. Word lists in German, English and Polish mark wording that may exclude applicants, for example because of age, gender, origin, language, appearance or family. The AI rates each passage in context, suggests neutral alternatives and title variants and points out requirements that look excessive. The code checks the answer: every quote must be in your ad, and alternatives and titles must not contain figures that are not in it. Missing pay appears as a placeholder such as [amount]. You get a checklist with the status fine, check, risk or missing.
Do4U finds hints and builds drafts. It never gives a legal verdict. You check each point and decide what to publish.
Sources
- EUR-Lex: Directive (EU) 2023/970 of 10 May 2023 on pay transparency, Articles 5 and 34 (eur-lex.europa.eu)
- Poland: act of 4 June 2025 amending the Labour Code (Dz.U. 2025 item 807), Polish text (PDF), eli.gov.pl (eli.gov.pl)
- Germany: § 11 General Equal Treatment Act (AGG), job advertisements, German text, gesetze-im-internet.de (www.gesetze-im-internet.de)
- Germany: § 1 General Equal Treatment Act (AGG), purpose and grounds, German text, gesetze-im-internet.de (www.gesetze-im-internet.de)
- Germany: Pay Transparency Act (EntgTranspG), full text, last amended on 5 July 2021, German text, gesetze-im-internet.de (www.gesetze-im-internet.de)