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Poland's President signed amendments to the Act on the State Labour Inspectorate on April 2, 2026, effective July 8, 2026. Inspectors can now issue binding administrative decisions reclassifying civil-law contracts (e.g., B2B agreements) as employment relationships. Maximum fines for labour violations increase from PLN 1,000–30,000 to PLN 2,000–60,000. Employers may request individual interpretations on contract classification and have a 12-month transitional period (until July 8, 2027) to voluntarily convert qualifying arrangements to employment contracts without penalties. The law also permits remote inspections and interim court relief.
Poland grants State Labour Inspectorate power to reclassify contracts and doubles maximum fines, effective July 8, 2026
Poland's President signed amendments to the Act on the State Labour Inspectorate on April 2, 2026, granting inspectors authority to issue binding administrative decisions that reclassify civil-law contracts as employment relationships. The law takes effect on July 8, 2026. Maximum fines for labour violations increase from PLN 1,000–30,000 to PLN 2,000–60,000.
Who is affected
All employers in Poland, particularly those engaging workers under civil-law contracts such as B2B agreements or contracts for specific work (umowa o dzieło). Workers performing tasks under conditions characteristic of employment—subordination, regular hours, employer-provided tools—are also affected. No company-size threshold applies; the amendments apply to all entities engaging contractors.
What's changing
Inspector reclassification authority:
State Labour Inspectorate (PIP) inspectors can now issue administrative decisions confirming the existence of an employment relationship. The procedure is two-stage: the inspector first orders the employer to eliminate the breach; if the employer does not comply, formal proceedings begin and a constitutive decision is issued. The employment relationship arises as of the decision date. Employers may appeal to a labour court within one month.
Individual interpretations:
Employers may request individual interpretations from the Chief Labour Inspector on whether a specific legal relationship qualifies as employment.
Fine increases:
| Violation type | Old maximum (PLN) | New maximum (PLN) |
|---|---|---|
| Labour code breaches | 30,000 | 60,000 |
| Minimum fine | 1,000 | 2,000 |
Remote inspections:
PIP may conduct remote inspections in justified cases.
Interim court relief:
Labour courts may grant interim relief in proceedings to establish employment relationships.
What NEO partners and clients should do
- By July 8, 2026: Review all civil-law contracts in Poland to assess whether working conditions (subordination, regular hours, employer-provided tools) meet the criteria for an employment relationship.
- By July 8, 2027: Use the 12-month transitional period to voluntarily convert qualifying civil-law arrangements to employment contracts without penalties.
- Ongoing: Prepare for potential PIP inspections, including remote audits. Document the commercial independence of contractors (separate invoicing, multiple clients, own equipment).
- If uncertain: Request an individual interpretation from the Chief Labour Inspector on contract classification before July 8, 2026.
