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Blazej Mrozinski

legitnyhr

Co-founder Compliance & HR Tech www.legitnyhr.com

I co-founded legitnyhr with Dorota Piekarska, Magdalena Raniszewska, and Marcin Ostrowski to do one specific kind of work properly: wartościowanie stanowisk (job evaluation), pay-gap reporting, and the operational side of bringing organizations into compliance with the EU Pay Transparency Directive (2023/970). It’s a Polish boutique consultancy — small number of concurrent engagements, founders do the work directly, no junior account managers between strategy and execution.

The four of us contribute different things. I run the methodology side: how a job-evaluation instrument gets designed across the four mandatory pillars (skills, effort, responsibility, working conditions), how scoring rationale gets captured so it survives audit, how worker categories get grouped into reproducible Article 9 reporting units, and how the statistical layer of a pay-gap report holds up under scrutiny. Dorota Piekarska brings the operational HR and Total Rewards depth — pay-structure design, the work with client teams, the daily mechanics of running an engagement inside a real organization. Magdalena Raniszewska of Kancelaria RBR covers the legal layer — tech-employment law, AI governance, RODO and AI Act compliance, and the intersection of labour law and tooling that determines whether a methodology choice is also defensible. Marcin Ostrowski builds the technical side: the engagement architecture, the AI integrations, and the data continuity that means clients walk away with everything they need.

How We Work

Single-team boutique. Founders do the work directly, capped concurrent engagement count, no junior account managers. Each engagement walks the same disciplined arc: methodology design → JD authoring → scoring with rationale on every score → grading into non-overlapping bands → worker-category grouping (Article 9 reporting units) → optional compa-ratio diagnostics and what-if pay scenarios → Article 9 GPG report → 8-phase Harmonogram → PDF evidence package the client takes home.

The deliverable is the evidence package — methodology document, JD scoring matrix, grading bands, worker categories, Article 9 GPG report, Harmonogram, with appendices for compa-ratio diagnostic and prescriptive scenarios when in scope. Clients own the output and can defend it if a labour inspectorate (PIP) asks. The app at app.legitnyhr.com is the production engine, not the product. Clients never log in. The tool exists so that we can run engagements quickly and reproducibly without methodology drifting between projects — every score gets rationale, every methodology lock is immutable, every report regenerates the same numbers months later.

Pay as Construct

Job evaluation, at the methodology level, is psychometric construct measurement applied to roles rather than people. The instrument has to discriminate fairly across job families with different shapes of work — production line, customer success, engineering, board — and produce a grading structure with non-overlapping bands that survives independent audit. The same disciplines that ran through assessment design at Gyfted and capability evaluation at Nerds.family — defining a construct precisely, choosing item formats that discriminate, validating that the instrument measures what it claims — sit underneath every legitnyhr engagement.

Article 9 GPG reporting takes this further: it’s statistical analysis with a legal threshold. The directive requires that any worker category with an unjustified gender pay gap above 5% triggers a remediation pathway. Missing-sex data has its own threshold logic — hard-block above 10%, exclude below 10%, warn between. The math has to be right, the assumptions documented, the headcount-by-RJR (“roczne jednostki robocze”, annual labour units, not raw FTE) computed correctly, and the no-proration rule (gap math runs on raw amounts, not annualised) applied in the right places. Measurement rigor isn’t decorative in this domain — it’s the auditable evidence trail.

Why Now

The EU Pay Transparency Directive (2023/970) is the substantive change. It turns previously-optional pay-fairness work into mandatory reporting with sanctions — in Poland, 2,000–60,000 PLN per the March 2026 PIP-Act amendment (Dz. U. 2026 poz. 473). The first Polish reporting period is the 2027 calendar year, with reports due 7 June 2028. The vacatio legis has run out for organizations of every cohort size, uniform across ≥150, 100–149, and <100 headcounts.

The regulation asks for two things at once: legal accuracy on the methodology side and statistical defensibility on the gap-math side. That’s an uncomfortable middle for both pure law firms (which can read the act but rarely the IRT-flavoured fairness logic underneath) and pure HR consultancies (which run job-evaluation projects but rarely with formal psychometric grounding or reproducible audit trails). legitnyhr is built for that middle: measurement, law, and tooling under one roof, with the methodology rigour to defend the work to a regulator and the implementation depth to ship it on time. More at www.legitnyhr.com.