On 11 March 2026, the Polish Senate adopted an amendment to the Act on the National Labour Inspectorate, significantly reshaping the regulatory framework of the Polish labour market. The new provisions not only equip inspectors with powerful tools to combat the misuse of civil law contracts, including B2B arrangements, but also establish an integrated oversight system under which no business can remain unnoticed. A lack of professional preparation for these new inspection standards may expose companies operating in Poland to severe financial risks.
Changes to PIP’s Powers – When Will They Come into Force?
The core provisions of the new regulations will enter into force three months after the date of promulgation of the Act. However, certain exceptions apply—provisions concerning, among others, the strategy for strengthening PIP’s operational capacity, IT security audits, and the establishment of an inter-agency task force will take effect as early as the day following publication. This means that the administrative apparatus in Poland will begin preparing for targeted enforcement actions almost immediately.
The End of the Civil Law Contracts Era in Poland? Administrative Decision Instead of Court Ruling
The most significant risk for employers is the new power granted to the National Labour Inspectorate (PIP) to determine the existence of an employment relationship by way of an administrative decision. Until now, a PIP inspector could only issue a recommendation or file a claim with a court if they concluded that a B2B arrangement exhibited characteristics of an employment relationship. Under the new rules, if an inspection reveals that a civil law contract is performed under conditions typical of an employment contract, a regional labour inspector will be able to unilaterally reclassify its status by issuing a formal decision.
Such a decision will trigger immediate legal consequences under Polish labour law, tax regulations, and social security rules. Moreover, once issued, the date of conclusion of the employment contract will be deemed to be the date of the decision—unless the employer attempts to terminate the contract during the inspection. In such a case, the effect will be applied retroactively to the date on which the inspection activities commenced.
Digital Oversight by ZUS, PIP and KAS – “Big Brother” Is Watching
Businesses must prepare for a new reality of digital oversight in Poland. The Act formalises a close cooperation framework between the authorities—PIP, the Social Insurance Institution (ZUS), and the National Revenue Administration (KAS). These bodies will exchange data in real time via a dedicated ICT system.
- KAS will provide PIP and ZUS with data covered by tax secrecy, derived from tax declarations.
- ZUS will share with PIP detailed information on insured individuals, contribution payers, contribution bases, and even occupational codes.
- PIP, in turn, will inform ZUS about inspection results and the amounts of assessed liabilities.
A joint risk assessment task force will ensure that inspections are precisely targeted at entities where data analysis indicates a likelihood of irregularities. Inspectors will also gain the authority to conduct remote inspections, hearings, and the online transmission of documents.
Severe Financial Consequences – Lack of Expertise May Lead to Bankruptcy
The legislator has increased the financial penalties for violations of employee rights.
New financial penalty thresholds for breaches of labour law
- Violations of regulations concerning the conclusion of employment contracts (e.g. replacing them with civil law contracts) are now subject to fines ranging from PLN 2,000 up to as much as PLN 60,000 (previously up to PLN 30,000).
- In cases of repeated offences or particularly serious breaches, fines may range from PLN 3,000 to PLN 90,000.
- The maximum penalty notice that can be imposed directly by a labour inspector has increased to PLN 5,000.
However, these penalties are only part of the burden for employers operating in Poland. A far more significant financial consequence arises from the moment PIP issues a decision reclassifying a B2B contract as an employment contract—the cost of employing such a contractor will increase substantially.
Moreover, such a decision by PIP is highly likely to trigger an inspection by ZUS. This may result in ZUS issuing decisions retroactively for up to five years, obliging the entrepreneur to pay outstanding social security contributions together with interest—calculated as if the parties had originally entered into an employment contract rather than a B2B arrangement.
Safeguarding a business against such consequences requires expertise that goes beyond standard HR capabilities. Although an entrepreneur may apply for an individual ruling from the Chief Labour Inspector (fee: PLN 40), the process is formalised and requires a precise and comprehensive presentation of the factual circumstances.
Is Your Company Prepared for the New PIP Inspection Regulations?
Nowe przepisy to jasny sygnał: państwo zyskuje pełny wgląd w strukturę zatrudnienia w każdej firmie. Zlekceważenie tych uprawnień lub próba samodzielnego „łatania” umów bez wsparcia kompetentnych ekspertów może skończyć się nie tylko zmianą formy zatrudnienia pracowników wstecz, ale przede wszystkim potężnymi konsekwencjami finansowymi, które mogą zachwiać płynnością finansową przedsiębiorstwa. Czas na audyt form zatrudnienia jest teraz – zanim systemy ZUS, KAS i PIP wytypują Twoją firmę do kontroli.
The new regulations send a clear message: the state is gaining full visibility into the employment structures of companies operating in Poland. Ignoring these powers or attempting to “patch” contractual arrangements independently, without the support of qualified experts, may result not only in the retroactive reclassification of employment relationships, but above all in substantial financial consequences that could undermine a company’s liquidity.
Now is the time to conduct an audit of employment arrangements—before the systems of ZUS, KAS and PIP identify your company for inspection.
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