Below is a summary of the most important changes and announcements from October 2025 that will impact the functioning of businesses and the situation of employees.
Breakthrough in Employment Tenure - President Signs Amendment to the Labour Code
The most significant news in October was undoubtedly the President’s signing of the amendment to the Labour Code on 15 October 2025, which fundamentally changes the rules for calculating employment tenure. The act was published in the Journal of Laws on 21 October 2025 (item 1423).
The new regulations standardise the rules for calculating employment tenure by including various forms of professional activity that were previously omitted.
The following periods will now be included in employment tenure, among others:
- periods of running a non-agricultural business and cooperation with a person conducting such a business,
- periods of suspension of business activity by an entrepreneur for the purpose of providing personal childcare,
- periods of performing a contract of mandate (umowa zlecenia),
- provision of services, agency contracts, and periods of being a cooperating person,
- periods of membership in an agricultural production cooperative and agricultural machinery cooperative,
- documented periods abroad of performing gainful work other than employment.
The new regulations will enter into force in two stages:
- 1 January 2026 for the public sector (employers constituting units of the public finance sector).
- 1 May 2026 for the private sector (the first day of the month following the lapse of 6 months from the publication date of the act, i.e., 21 October 2025).
The newly recognised periods will be confirmed primarily based on certificates issued by the Social Insurance Institution (ZUS), upon an application submitted electronically via the PUE/eZUS system, which will be available from 1 January 2026.
Employees will have 24 months from the date the act enters into force (depending on the sector) to document the newly included periods to their current employer.
End of Printing ZUS Registration Forms
On 24 October 2025, an act deregulating the obligations of contribution payers was published.
The amendment (Journal of Laws 2025, item 1409), entering into force on 4 November 2025, abolishes the obligation to print, collect signatures from employees, and store for 5 years paper versions of insurance registration forms (e.g., ZUS ZUA, ZUS ZZA) that have been submitted electronically.
Source: portal prawo.pl
Free Qualified Electronic Signature in mObywatel
On 24 October 2025, it was announced that users of the mObywatel application can now sign documents with a qualified electronic signature free of charge (up to five times per month).
Poland is the first EU country to provide such a solution within a government application, aiming to facilitate the digital handling of official and private matters.
Source: portal gov.pl
Postponement of Excluding Allowances from the Minimum Wage
The government has decided to postpone the introduction of regulations that would gradually exclude certain allowances from the minimum wage.
This decision, announced on 7 October 2025, is justified by the need to ease the financial burden on businesses and the state budget, as the new rules would increase payroll costs, particularly in the public sector.
Revised schedule for excluding components from the minimum wage:
- Functional allowance: from 1 January 2027 (originally 2026)
- Other allowances: from 1 January 2028 (originally 2027)
- Bonuses and awards: from 1 January 2029 (originally 2028)
Source: portal gazetaprawna.pl
Business Travel - Clarifications from PIP
In October, the National Labour Inspectorate (PIP) clarified that labour law regulations do not require a written business travel order — an oral instruction is sufficient.
However, the order must clearly specify the task, the timeframe, the place of execution, and the means of transport.
Source: portal infofk.pl
OHS Obligations During the Winter Season
On 13 October 2025, a reminder was published regarding employers’ obligations related to the winter season, which under occupational health and safety (OHS) regulations is defined as lasting from 1 November to 31 March.
Employers must ensure, among other things:
- a minimum temperature in workrooms (not lower than 14°C; in office spaces or for light physical work not lower than 18°C),
- hot beverages when outdoor work is performed and the ambient temperature falls below 10°C,
- regeneration meals for employees performing work involving physical effort exceeding specified caloric thresholds.
Source: portal infor.pl
Day Off for the 1 November Public Holiday
As All Saints’ Day (1 November) falls on a Saturday, the Chief Labour Inspector clarified in October that employees for whom Saturday is a non-working day must be granted an additional day off. The employer decides when this day off is granted, but it must fall within the same settlement period in which the holiday occurred.
Source: portal prawo.pl
Proposal to Introduce Electronic Occupational Health Certificates
On 16 October 2025, the Ministry of Health published a draft regulation introducing an electronic format for issuing occupational health medical certificates. These certificates will be stored in the Medical Information System (SIM) and made available in the Internet Patient Account (IKP). The option to issue certificates in paper form will remain available.
Source: portal inforlex.pl
Extension of Legal Stay for Ukrainian Citizens
On 3 October 2025, information was published regarding changes that extended the legal stay of selected groups of Ukrainian citizens in the territory of the Republic of Poland until 4 March 2026. This applies to individuals who arrived in Poland due to the military actions beginning on 24 February 2022, as well as those whose stay on other grounds expired after that date.
Source: portal gov.pl
The changes introduced in October show that labour law and social insurance are entering a new era — one that is more flexible, digital, and aligned with the realities of today’s labour market.
For employers, this is the right moment to update internal procedures and prepare for upcoming obligations, while for employees it is an opportunity to make better use of their professional experience to date.
It is worth planning ahead now to enter 2026 without surprises. If You need support from experienced HR and payroll specialists, don't hesitate to contact us.