The upcoming changes focus on improving pay transparency, regulating internship and placement arrangements, and strengthening employee protection against workplace bullying and harassment. To navigate this new professional landscape with confidence, it is worth familiarising yourself with the key amendments now. Below are the most important changes that will come into force in 2026.
Minimum Wage – What Counts and What Doesn’t? Is an Amendment to the Employment Contract Necessary?
The statutory minimum wage applicable from 1 January 2026 has been set at PLN 4,806.00 gross. This amount serves as the basis for many payroll calculations: it is used to determine the night work allowance (equal to 20% of the hourly rate derived from this wage) as well as the amounts exempt from deductions.
Changes to the employment contract due to an increase in the minimum wage – is an amendment required?
Information about remuneration corresponding to the type of work performed, together with an indication of its components, is one of the elements that must be included in an employment contract under Article 29 § 1(3) of the Polish Labour Code. However, this provision does not specify the manner in which this information should be presented.
Any change to the terms of an employment contract must be made in writing, in accordance with Article 29 § 4 of the Labour Code.
In its judgment of 3 November 1976 (case no. I PR 165/76), the Supreme Court stated that:
“Remuneration — as an essential element of every employment contract — should be defined precisely, leaving no doubt as to the rules for its payment agreed by the parties.”
Pursuant to Article 6(1) of the Act of 10 October 2002 on the Minimum Wage for Work (Journal of Laws of 2020, item 2207), the remuneration of an employee employed on a full-time basis may not be lower than the statutory minimum wage.
If the basic salary in the employment contract has been stated as a fixed amount equal to the minimum wage and no other pay components have been provided (as in the example described above), any change in the minimum wage rate requires the employment contract to be updated — for example, by means of an amendment.
To avoid the need to amend employment contracts every time the minimum wage increases, an employer may change the wage clause from a fixed amount to a reference to the statutory regulations (e.g. by way of an amendment). In addition, although this is not a legal requirement, employers may inform employees about the current minimum wage, for example by posting it on a notice board — this is considered good HR practice.
Example:
From 1 January 2025, an employer hires an employee on a full-time basis for a production role, with remuneration set at the minimum wage rate. The employment contract states the amount of PLN 4,666.00. Due to the increase to PLN 4,806.00 effective from 1 January 2026, the employer provided the employee with an amendment at the end of December, stating:
“As of 1 January 2026, the employee shall be entitled to remuneration in the amount of the minimum wage for work referred to in Article 6(1) of the Act of 10 October 2002 on the Minimum Wage for Work (Journal of Laws of 2020, item 2207).”
Salary Must Be Disclosed in Job Ads. No More Secret Salaries
As of 24 December 2025, pay secrecy in the recruitment process will become a thing of the past.
The new regulations require employers to provide candidates with information about the starting salary or the salary range (so-called “pay bands”). This information must be provided at one of three stages:
- directly in the job advertisement,
- before the job interview,
- or—at the latest—before entering into an employment relationship.
Crucially, the disclosed amount must include all components of remuneration, as well as any other cash and non-cash benefits related to the job, not only the basic salary. Moreover, a strict ban has been introduced on asking candidates about their previous earnings in former workplaces.
This is one of the most significant changes in recent years, aimed at promoting pay transparency and preventing disparities, particularly those based on gender. As a result, candidates’ negotiating position will be significantly strengthened, and salary levels should be determined by skills and the market value of the role, rather than by pay history from previous employment. In addition, all job advertisements and job titles will have to be formulated in a gender-neutral manner.
A New Definition of Workplace Bullying and Higher Compensation for Victims
The planned amendments to the Polish Labour Code are intended to strengthen employee protection against workplace bullying (mobbing).
The new, simplified definition of this phenomenon will refer to persistent harassment that is repetitive, recurring, or continuous. The regulations will explicitly exclude isolated, one-off incidents which, although they may violate personal rights, will not be classified as mobbing.
For employees, two key changes are particularly important:
- Introducing a minimum, guaranteed level of compensation for victims of mobbing. The final proposal assumes that it may not be lower than 12 times the statutory minimum wage, which represents a stricter approach compared to earlier drafts.
- Imposing an obligation on employers to actively and continuously prevent mobbing. This means the need to implement specific preventive measures, mechanisms for detecting undesirable behaviour, and corrective actions.
Importantly from the employer’s perspective, the draft also introduces a kind of “defence shield.”
A company may be released from civil liability if it proves that it has implemented effective, documented preventive measures, and that the mobbing did not come from the victim’s supervisor. This solution highlights the crucial role of real, practical anti-bullying policies, not merely formal procedures on paper.
HR Applications and Company Documents Now Available in Electronic Form
The upcoming changes mark a major step towards HR digitalisation and the modernisation of HR processes in Poland.
Many HR applications and employee declarations that previously required a written (paper-based) form will now be submitted and received in electronic format. The goal is to simplify and speed up communication between employees and employers, while supporting more efficient HR administration and reducing paperwork.
Examples of HR documents covered by digitalisation include:
- an application for unpaid leave,
- an application for an individual or flexible working time schedule,
- an application for time off in lieu for overtime work,
- confirmation of having read and understood occupational health and safety (OHS) regulations,
- notification to the company trade union organisation of the intention to terminate an employment contract.
The Deadline for Paying Out Unused Annual Leave Compensation Will Change
One change that will significantly streamline the work of HR and payroll departments concerns the timing of the cash compensation for unused annual leave upon termination of employment.
Until now, the employee’s entitlement became due on the last day of work.
Under the new regulations, as a general rule, the unused holiday pay compensation will be paid on the company’s standard salary payment date.
However, one exception will apply:
if the salary payment date falls before the employment contract ends, the employer will have 10 days from the termination date to pay the unused leave compensation.
This amendment is intended to simplify final payroll settlements and reduce the risk of errors caused by the need to complete all formalities immediately at the end of employment.
Electronic Confirmation of Initial OHS (Health and Safety) Training
As of 12 December 2025, new provisions of the Regulation of the Minister of Family, Labour and Social Policy have entered into force. In addition to the written form, the regulations now allow employers to confirm that an employee has completed both general OHS training and job-specific OHS training in the initial health and safety training record in electronic format.
In such cases, the employer is required to make an appropriate note in the initial training record in the space designated for a signature and attach an electronic document containing the confirmation or its digital copy.
These confirmations form an integral part of the initial OHS training record and must be stored by the employer in the employee’s personnel file.
SODiR (PFRON) – Mandatory Password Change
PFRON (the Polish State Fund for Rehabilitation of Disabled Persons) has published an update regarding changes to the password policy in SODiR — its online system used by employers to handle selected subsidies and reimbursements.
Under the new rules, users must change their password to a new one no later than 31 March 2026.
After this deadline, logging in with the old password will no longer be possible. Users who fail to update their password on time will be required to submit a written request to obtain a one-time password, which may significantly extend the time needed to regain access to the system.
Make sure your company is ready for 2026.
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