Poland's New Gender Quota Law for the Governing Bodies of Certain Companies Enters into Force
On 17 August 2026, Poland's law implementing the EU Women on Boards Directive (Directive (EU) 2022/2381 of the European Parliament and of the Council of 23 November 2022 on improving the gender balance among directors of listed companies and related measures) entered into force. Large public companies must ensure that the underrepresented sex holds a share as close as possible to 33% of seats – separately in both the management board and the supervisory board. The first compliance report is already due by 31 October 2026, and non-compliance can trigger a fine of up to PLN 500,000 from the Polish Financial Supervision Authority (KNF).
Who is affected
The requirement applies to Polish public companies whose shares are admitted to trading on a regulated market in at least one EU member state, regardless of industry – this is a general obligation for large public businesses, not a sector-specific one. It applies to the issuer as such, covering both its management board and its supervisory board.
Micro, small, and medium-sized enterprises are excluded – companies with fewer than 250 employees, annual turnover below EUR 50 million, or a balance sheet total below EUR 43 million, even if their shares are publicly traded.
What this means for the Polish market
Of the 107 companies in the WIG140 index, only 12 currently meet the requirement. In other words, the vast majority of Polish public companies will need to change the composition of their governing bodies, or at least the procedures used to form them.
What's changing
Quota: the share of the underrepresented sex (defined as holding no more than 49% of seats) must be at least as close as possible to 33% of all seats on the relevant body – and this requirement applies separately to both the management board and the supervisory board.
Companies must adopt a gender balance policy by resolution of the general meeting, by the end of the first general meeting held after the law enters into force (extendable to up to four months if that meeting takes place within two months of the law's entry into force).
Candidates for governing bodies must be assessed solely against non-discriminatory and clearly defined qualification criteria; where candidates are equally qualified, preference goes to the candidate of the underrepresented sex.
Annual reporting: companies must disclose the number of people on each body by sex and position, the measures taken, and – if the target has not been met – the reasons and an action plan. The report must be published on the company's website immediately after it is prepared and submitted to the relevant government authority by 30 June each year (or within six months of the financial year-end if included in the activity report). The first reports are due by 31 October 2026.
What this means for business – recommendations
- Audit the current composition of the management board and supervisory board against the ~33% quota, checked separately for each body.
- Adopt a gender balance policy at the next general meeting, keeping the shortened deadline in mind.
- Review and document candidate selection procedures for governing bodies, formalizing non-discriminatory evaluation criteria.
- Prepare the first gender balance report by 31 October 2026.
- Factor in the risks: a KNF fine of up to PLN 500,000, plus potential compensation claims from underrepresented candidates – with the burden of proof shifted to the company.
Write to our lawyer to learn more
Write to a lawyer